Tag: Mazda

Russia vs Mazda Motors, October 2015, Supreme Court, Case No. А40-4381/13

Russia vs Mazda Motors, October 2015, Supreme Court, Case No. А40-4381/13

A Russian subsidiary of the Mazda Motors Group had been claiming losses. Following an audit the tax authorities concluded that losses for FY 2009, was due to overstatement of the purchase prices of Mazda cars. An assessment was issued where the pricing was determined using the Resale Price Method, resulting in additional income of 1,362,172,034 rubles. The Arbitration Court held in favor of the tax authorities and this decision was upheld by the Arbitration Court of Appeal. The decision was then appealed to the Supreme Court. The Supreme Court denied the appeal and upheld the decision of the Arbitration Court. Click here for English Translation RSC Mazda A40-4381-2013_20151014 ... Read more
Russia vs Mazda Motors, March 2015, Arbitration Court of Moscow, Case No. А40-4381/13

Russia vs Mazda Motors, March 2015, Arbitration Court of Moscow, Case No. А40-4381/13

A Russian subsidiary of the Mazda Motors Group had been claiming losses. In the opinion of the tax authority, the losses incurred by the Russian distributor were mainly due to non-arm’s length transfer pricing within the group of companies. An assessment was issued where the pricing had been determined using the Resale Price Method. Decision of the Russian Arbitration Court “Having evaluated the arguments of the parties and the evidence presented in the case, taking into account the provisions of Art. 71 APC RF, the appeal court considers the conclusions of the court of first instance as motivated, consistent with the circumstances of the case and the requirements of the law. In the presence of these circumstances, the claims claimed by the company were rightly rejected by the court of first instance. Thus, the decision of the court is legal and justified, corresponds to the materials of the case and the current legislation, in connection with which it is not ... Read more