Tag: LNG
Liquefied natural gas, a cryogenically cooled form traded globally as a commodity. In transfer pricing, LNG transactions are disputed where tax authorities challenge profit allocation, management fees, and restructurings within integrated energy groups handling LNG supply chains.
France vs SA Engie, June 2024, CAA Paris, Case No 21PA01277
SA Engie, the French holding company of the Engie energy group, operated a 'single voice' arrangement for liquefied natural gas trading through intra-group service agreements with its US and Luxembourg subsidiaries. French tax authorities challenged the arm's length remuneration for these services. The Paris Court of Appeal ruled in favour of the taxpayer in 2024, finding the tax authority had not discharged its burden of proof regarding the pricing of the LNG scheduling, shipping, and cargo transactions ... Read more