Íslenska kalkþörungafélagið ehf. ("the Icelandic Limestone Algae Company") operated a calcified algae factory in Iceland, harvesting seaweed from the seabed, cleaning, drying and exporting it almost entirely to its Irish parent company, Marigot Ltd. Marigot Ltd. further processed the raw material in ... Read more

Delmonte Kenya, an integrated pineapple producer and exporter, argued it should be characterised as a routine cost-plus producer with residual profits attributed to foreign group entities. The Kenya Revenue Authority challenged the pricing, functional characterisation, and documentation, asserting Delmonte Kenya bore key risks and created core value. The Tax Appeal Tribunal ruled in favour of the tax authority in January 2026, rejecting the taxpayer's tested party selection and benchmarking approach ... Read more

Following a tax audit, the Tanzania Revenue Authority disallowed IT expenses claimed by Nyota Tanzania Limited on the basis that the taxpayer failed to substantiate that services had been rendered or that charges were arm's length. The Tax Revenue Appeals Board, Tribunal, and ultimately the Court of Appeal of Tanzania all upheld the disallowance in 2025, confirming that the burden of proof rests with the taxpayer to evidence related-party service deductions ... Read more

A Tanzanian branch of UK-incorporated Aggreko International Projects Limited claimed deductions for head office and Dubai regional hub costs allocated on a pro rata revenue basis for 2018 and 2019. The Tanzania Revenue Authority disallowed the expenses citing insufficient documentation and failure to prove costs were wholly and exclusively for Tanzanian income production. The Tax Revenue Appeals Board and the Court of Appeal both upheld the disallowance, along with associated interest and penalties ... Read more

Williamson Diamonds Limited, operator of a major Tanzanian diamond mine, disputed transfer pricing adjustments made by the tax authorities over intra-group diamond sales and management fees paid abroad. The authorities disallowed deductions for inadequately documented service charges. The Tax Appeals Tribunal and Tanzania Court of Appeal upheld the assessments in 2025, finding the company failed to provide sufficient comparability analysis under Tanzanian transfer pricing regulations ... Read more

EET Group A/S, a Danish IT components reseller, faced transfer pricing adjustments for 2010–2012 after tax authorities claimed its distribution companies earned more than comparable low-risk distributors. The Danish Supreme Court upheld the Court of Appeal's ruling in favour of the taxpayer, finding the transfer pricing documentation was not significantly deficient and that margins falling outside the interquartile range alone did not prove non-arm's length pricing ... Read more

A Colombian company had interest deductions on loans from a British Virgin Islands related party disallowed after tax authorities found its transfer pricing documentation deficient. The taxpayer relied solely on US corporate bond comparables, which authorities rejected as insufficiently similar. Colombia's Supreme Administrative Court upheld the adjustments in 2025, finding the taxpayer failed to disprove the authority's findings or demonstrate flaws in the comparability analysis ... Read more

A Greek retailer deducted royalties for trademarks and know-how and management service fees paid to a Dutch affiliate. The tax authority disallowed both, citing vague contracts, lack of proven benefit, and a flawed CUP study that ignored internal licensing comparables. The Administrative Tribunal upheld the assessment in April 2025, finding the documentation inadequate and the transfer pricing study non-compliant with OECD Guidelines ... Read more

A Greek company sought to deduct management service fees paid to group entities, but the tax authority disallowed the expenses due to vague contracts and insufficient documentation. The Administrative Court of Appeal upheld the assessment, finding the company had not proven the services were actually rendered or served its business needs. In March 2025, the Greek Supreme Administrative Court dismissed the company's appeal, confirming the fees were correctly treated as non-deductible ... Read more

A Peruvian airline claimed deductions for intra-group service payments, arguing they were necessary within the corporate group and subject to OECD transfer pricing principles. The tax authority disallowed the deductions due to insufficient documentation proving the services were actually rendered. Peru's Tax Court dismissed the appeal in March 2025, ruling that taxpayers must substantiate that transactions occurred with reliable evidence before transfer pricing rules even become relevant ... Read more

A Kenyan subsidiary of a South African construction group claimed deductions for expatriate salary costs totalling Kshs 46 million in FY 2013. The Kenya Revenue Authority disallowed the deductions for insufficient documentation. On remittal from the High Court, the Tax Appeal Tribunal upheld the disallowance in 2025, finding that intercompany invoices alone were inadequate without employment contracts, assignment letters, or work permits ... Read more

An Icelandic producer of calcareous algae sold its production to its Irish parent company using a cost-plus method that excluded payroll expenses and depreciation from the cost base. The Icelandic tax authorities rejected the approach as non-compliant with OECD guidelines and found the transfer pricing documentation insufficient. The District Court ruled in favour of the tax authorities in February 2025, upholding the assessments covering tax years 2016 to 2020 ... Read more

A Danish life-saving equipment manufacturer sold products to foreign subsidiaries at lower prices than to unrelated distributors. The tax authority challenged the pricing using TNMM and a benchmark study applying the interquartile range and median adjustment. The district court initially overturned the assessment, but Denmark's Court of Appeal reversed that decision in February 2025, upholding the tax authority's arm's length adjustment ... Read more

Accenture A/S faced tax assessments on two intra-group transactions: temporary loans of idle employees and royalty payments for intangibles legally owned by a Swiss group entity. The Danish tax authority challenged the arm's length nature of both arrangements. After the Court of Appeal ruled against the taxpayer in 2023, Denmark's Supreme Court reversed that decision in January 2025, finding in favour of Accenture A/S on both issues ... Read more

Capitaria S.A. segmented its financial statements to isolate income from a joint venture with related BVI entity KT Financial Group, reporting a 69.24% operating margin. Chilean tax authorities challenged the segmentation methodology, alleging tax base erosion risks. The District Court and subsequently the Court of Appeal in 2024 both ruled in favour of the taxpayer, confirming that the segmented results adequately demonstrated the joint venture's profitability and were supported by sufficient documentary evidence ... Read more

A Peruvian airline claimed deductions for intra-group aircraft leasing and related costs passed down from a group parent. The tax authority disallowed the deductions, finding insufficient documentation to prove the services were actually rendered to the taxpayer, including missing block hour records and per-entity billing. The Tax Court upheld the authority's position in September 2024, confirming that benefit test documentation must be specific and reliable ... Read more

A Kenyan tobacco company argued that full-cost-mark-up transfer pricing adjustments explained variances between its CIT and VAT declarations on export sales. The Kenya Revenue Authority challenged the adjustments due to missing documentation. The Tax Appeal Tribunal ruled against the taxpayer in 2024, finding that failure to produce the actual transfer pricing policy or sufficient supporting evidence prevented validation of arm's length compliance ... Read more

A wholly owned subsidiary of a South African multinational deducted management fees paid to its parent for intra-group services. The Eswatini tax authority disallowed part of the deduction, citing insufficient documentation, duplicated and shareholder services, inappropriate allocation keys, and tax avoidance under Section 65 of the ITO. The Revenue Appeals Tribunal upheld the assessment in favour of the tax authority in July 2024 ... Read more

Danish tax authorities raised EET Group A/S's taxable income by DKK 128 million for 2010–2012, alleging foreign sales companies were overcompensated as limited risk distributors. The National Tax Tribunal reduced the adjustment significantly. The Court of Appeal upheld the gross profit benchmarking approach, found the transfer pricing documentation adequate, and confirmed interquartile range narrowing, largely ruling in the taxpayer's favour ... Read more

Oleaginosa Oeste SA exported soybean and sunflower seed oil to a related party in Switzerland at prices the Argentine tax authority deemed not arm's length. The Tax Court and Court of Appeal partially annulled the assessment, but the Supreme Court overturned those decisions in 2024, finding that lower courts had failed to adequately examine the taxpayer's insufficient evidence regarding the date of sales, and remanded the case for reconsideration ... Read more

Italian tax authorities disallowed Gru Comedil s.r.l.'s deduction of intra-group management service costs, arguing insufficient documentation of actual benefit received. The case reached Italy's Supreme Court, which overturned the assessment in 2024, confirming that intra-group service costs are deductible where the recipient derives actual, objectively determinable utility that is adequately documented, ruling in favour of the taxpayer ... Read more

Walmart Chile S.A. deducted costs for inter-group management, marketing, and advertising services, along with interest on an intra-group loan, in its 2014 and 2015 tax returns. The Chilean tax authority disallowed these deductions following an audit. The Tax Court largely sided with the authority, and the Court of Appeal upheld that decision in March 2024, confirming the disallowances due to insufficient documentation ... Read more

Bayer S.A. sought a VAT credit refund based on a 2018 transfer pricing adjustment, arguing intercompany transactions qualified as exported services. Guatemala's Supreme Court dismissed the appeal in January 2024, finding that the debit notes lacked required information, were issued outside statutory time limits, and that Bayer had failed to prove the services met legal requirements for VAT export treatment under Guatemalan law ... Read more

A Tanzanian subsidiary of UK-based Aggreko International Projects Limited deducted allocated head office costs in FY2011–2012 for temporary power generation services. The Tanzania Revenue Authority adjusted the allocation, raising additional taxable income. The Tax Revenue Appeals Tribunal upheld the assessment, and the Court of Appeal dismissed the taxpayer's further appeal in September 2023, finding the deductions were insufficiently documented and the cost allocation unjustified ... Read more

A Danish consulting group faced tax authority challenges over two intra-group transaction types: temporary employee loans to operating companies and royalty payments for use of intangibles. The tax authority issued discretionary assessments citing insufficient documentation and lack of functional substance in the lending entities. The Danish Court of Appeal upheld both assessments in 2023, confirming the authority's right to reassess where transfer pricing documentation failed to reflect actual functions and risks ... Read more

A German automotive parts supplier transferred labour-intensive manufacturing to a wholly owned Bosnian subsidiary to reduce wage costs, retaining high-tech processes in Germany. The German tax authority challenged the transfer pricing arrangements, including royalty payments and location savings allocation. The Bundesfinanzhof ruled mostly in favour of the tax authority in August 2023, finding the taxpayer's documentation insufficient and upholding adjustments to the cross-border restructuring arrangements ... Read more

Four German operating companies manufactured and sold products under a group licence before the group relocated these activities to Switzerland. The German tax authority argued a taxable transfer of functions had occurred. The Finanzgericht ruled in favour of the taxpayer in August 2023, finding no assets, business opportunities, or functions were transferred, and no causal link existed between any transfer and the ability to exercise a function. An appeal is pending before the BFH ... Read more

A Danish company's transfer pricing documentation was found materially deficient by the Court of Appeal in 2023, as it failed to describe how prices were determined or provide adequate information about the related flow-through entity's business activities. SKAT was entitled to issue a discretionary assessment. The court also upheld withholding tax liability on transfers treated as taxable dividends under Danish corporation tax rules ... Read more

A Danish advisory company paid DKK 78.7 million in service fees to a related Dubai entity owned by the same sole shareholder across 2006–2010. The Danish tax authorities challenged the pricing as non-arm's length and reduced allowable fees to DKK 20 million. The Supreme Court upheld the discretionary assessment in November 2022, confirming that inadequate transfer pricing documentation justified the authority's adjustment ... Read more

Olympus Medical Systems India, a subsidiary of Olympus Corp, reported losses in FY 2012–2013 and failed to provide audited financials of its associated enterprises during a transfer pricing audit. The Indian tax authority applied the Residual Profit Split Method to benchmark AMP expenses using a Bright Line Test. The Delhi Income Tax Appellate Tribunal ruled in 2022 that Olympus could not benefit from its own non-cooperation and upheld the authority's approach, remanding the matter for re-examination ... Read more

A Swedish pharmaceutical company transferred the Restylane trademark to a Swiss related party and operated limited risk distribution in China. The Swedish Tax Agency challenged the valuation of the trademark transfer in 2011 and the arm's length remuneration for distribution in 2013–2014. The Administrative Court of Appeal upheld the tax authority's adjustments, finding independent parties would have used more recent sales figures, resulting in a significantly higher arm's length trademark value ... Read more

A Danish company providing legal services paid management fees to a foreign sister company controlled by its owner. The Danish tax authority challenged the pricing as non-arm's length and found the transfer pricing documentation deficient, issuing a discretionary assessment of DKK 58.4 million. The Danish Court of Appeal upheld the authority's position in 2021, confirming the use of the TNMM benchmarked against 25 comparable firms ... Read more

A Romanian gas distributor challenged a transfer pricing assessment concerning its natural gas purchase prices from an affiliated supplier. The tax authority applied the transactional net margin method, using ORBIS and FISCNET databases to identify six comparable EU companies after only one Romanian comparable qualified. The Court of Appeal dismissed the taxpayer's appeal in December 2020, upholding the assessment and confirming the arm's length benchmark methodology applied by the authorities ... Read more

A Luxembourg company obtained an advance tax agreement confirming that Mandatory Redeemable Preference Shares would be treated as debt, making dividend payments tax deductible. The tax authorities later challenged the 2013 return, demanding arm's length evidence. The Administrative Tribunal ruled in 2020 that the advance tax agreement was binding on the administration, provided the conditions for a valid agreement were met ... Read more

A German automotive supplier transferred labour-intensive manufacturing to a subsidiary in Bosnia-Herzegovina to reduce costs, while retaining high-tech processes in Germany. The tax authority challenged the transfer pricing arrangements surrounding the business restructuring and royalty payments. The FG Munich ruled mostly in favour of the tax authority in November 2019, finding the documentation insufficient and upholding adjustments to the intercompany arrangements ... Read more

A Romanian company challenged tax authority adjustments after an audit found deficiencies in its comparability study, covering royalties, support services, and strategic management fees. The tax authority replaced the study and disallowed carried-forward losses. Romania's Supreme Administrative Court ruled in favour of the tax authority in 2019, upholding the revised benchmark analysis and confirming the transfer pricing adjustments despite double taxation arguments raised by the taxpayer ... Read more

A Slovenian company failed to provide transfer pricing documentation and did not comply with tax authority instructions. The tax authority rejected the cost plus method, applied TNMM, and made a secondary adjustment treating the remaining pricing discrepancy as a hidden profit distribution. The Slovenia Administrative Court upheld the assessment in full in February 2018, ruling the tax authority had acted correctly throughout ... Read more

A Slovenian buy/sell distributor claimed tax deductions for intra-group service fees, product redemption and destruction costs, and royalty payments charged by related parties. The tax authority disallowed the deductions, and the Administrative Court upheld that decision in 2013, finding the distributor failed to prove services were actually received or necessary, was not obliged to bear product destruction costs given its functions and risks, and had no valid basis for deducting the royalty payments ... Read more

A Slovenian company sought to deduct costs for services charged by related parties, but the tax authority disallowed the expenses after finding no credible documentation proving the services were actually rendered. The Administrative Court upheld the decision in 2013, agreeing that insufficient evidence of actual service provision justified excluding the costs as non-deductible under Article 16 of the Corporate Income Tax Act ... Read more