Tag: Marine terminal
Port infrastructure used to receive, store, and transship cargo between rail, road, and sea vessels. In transfer pricing, authorities challenge whether fees charged for stevedoring and terminal services to related non-resident counterparties reflect arm’s length rates for comparable port logistics operations.
Ukrain vs “TIS -Mindozyriva”, May 2025, Supreme Administrative Court, Case № 420/22108/21 (K/990/41972/23)
A Ukrainian marine grain terminal operator successfully challenged transfer pricing assessments issued by the tax authority over 2015 controlled transactions with BVI and Swiss counterparties. The authority applied an external CUP method but failed to justify rejecting the taxpayer's internal comparable data. Ukraine's Supreme Administrative Court upheld lower court rulings annulling the assessments, finding the authority's comparability analysis and range construction methodologically unsupported ... Read more
Ukrain vs “TIS -Mindozyriva”, May 2025, Supreme Administrative Court, Case № 420/22108/21 (K/990/41972/23)
A Ukrainian marine grain terminal operator successfully challenged transfer pricing assessments issued by the tax authority over 2015 controlled transactions with BVI and Swiss counterparties. The authority applied an external CUP method but failed to justify rejecting the taxpayer's internal comparable data. Ukraine's Supreme Administrative Court upheld lower court rulings annulling the assessments, finding the authority's comparability analysis and range construction methodologically unsupported ... Read more