An Italian luxury watch and jewellery retailer purchased goods from its Swiss parent and reported losses, pricing transactions using the CUP method. The Italian Revenue Agency applied the TNMM with return on sales as the profit level indicator, issuing assessments totalling EUR 4.69 million. The company argued TNMM ranked lower in the method hierarchy and that losses stemmed from high rental costs. Italy's Supreme Court decided in favour of the tax authority in November 2025 ... Read more

A Bulgarian subsidiary acquired the Kameniza trademark from its Dutch parent for EUR 40.1 million, with installment payments made in 2017. The tax authority treated amounts exceeding the arm's length value as hidden profit distributions, imposing 5% withholding tax. Bulgaria's Supreme Administrative Court overturned the lower court's ruling in 2025, confirming that the 2009 acquisition price and OECD DEMPE guidance were legitimate valuation tools, not retroactive law ... Read more

Bunge Iberica SA participated in its group's cash pooling arrangement as both borrower and fund provider. Spanish tax authorities adjusted deposit and withdrawal interest rates symmetrically using a group credit rating. After rejections by the Tax Court in 2019 and the National Court in 2023, Spain's Supreme Court dismissed Bunge Iberica's final appeal in July 2025, confirming the tax authority's assessment and the limited risk role of the cash pool lead entity ... Read more

Bunge Iberica SA participated in its group's cash pooling arrangement as both borrower and fund provider. Spanish tax authorities adjusted deposit and withdrawal interest rates symmetrically using a group credit rating. After rejections by the Tax Court in 2019 and the National Court in 2023, Spain's Supreme Court dismissed Bunge Iberica's final appeal in July 2025, confirming the tax authority's assessment and the limited risk role of the cash pool lead entity ... Read more

A Polish fertilizer manufacturer transferred its trademarks to a subsidiary and paid royalties for their continued use. The tax authority recharacterised the licence agreement as a trademark management services contract and reduced deductions. Poland's Supreme Administrative Court ruled mostly in the taxpayer's favour in 2025, finding that pre-2019 rules did not permit transaction recharacterisation, and remanded the case for re-examination ... Read more

Kamenitza AD acquired a trademark from a related party for €40.1 million in 2014, but Bulgarian tax authorities argued the value was overstated, relying on a 2009 sale price via the CUP method. The company contested retroactive application of 2017 OECD DEMPE guidelines. After the administrative court upheld the tax assessment without independent analysis, the Supreme Administrative Court remanded the case for re-examination in January 2025 ... Read more

Meda AB, a Swedish pharmaceutical parent, established a Luxembourg subsidiary as contractual owner of acquired intangibles, retaining only routine compensation for group services. Swedish tax authorities reallocated profits based on actual risk control, but the Administrative Court of Appeal sided with Meda AB, finding that delineation based on risk control was inconsistent with Swedish arm's length provisions and the applicable OECD Transfer Pricing Guidelines ... Read more

A Polish company transferred trademark ownership to a subsidiary in 2010, paid licence fees, then repurchased the trademark in 2013, claiming depreciation deductions. The tax authority recharacterised the arrangement as a service contract, finding the subsidiary performed no DEMPE functions and that the repurchase price was inflated. The Provincial Administrative Court remanded the case for re-examination in June 2023 ... Read more

A Spanish branch performing IT distribution and marketing activities was assessed by tax authorities who adjusted its income to the median of a TNMM benchmark range and disallowed intra-group service fee deductions. The branch appealed, and Spain's TEAC partially upheld the appeal in January 2023, finding deficiencies in the tax authority's comparability analysis and burden of proof regarding the interquartile range adjustment ... Read more

A Polish fertilizer manufacturer transferred trademark ownership to a subsidiary and paid royalties for continued use. Tax authorities recharacterised the licence as administrative services, reducing deductions. The Regional Administrative Court ruled that pre-2019 Polish tax law did not permit transaction reclassification, only arm's length price adjustments, and remanded the case for proper reexamination of whether royalties met the arm's length standard ... Read more

A Greek dairy distributor was audited by the tax authorities, who determined that prices paid to related parties in FY 2017 exceeded the arm's length range and issued an upward taxable income adjustment. The company appealed, but the Administrative Tribunal dismissed the appeal in November 2021, fully upholding the tax authority's assessment and confirming the transfer pricing methodology applied ... Read more

A Belgian entity performed all key DEMPE functions for the Uniclic technology without remuneration, while royalty income flowed to a related Irish-registered entity. The tax authority sought to add foregone royalties to the taxpayer's taxable base, alleging a simulated transfer of invention rights. The Court of Appeal ruled mostly in favour of the taxpayer, finding the administration had not sufficiently demonstrated tax evasion or a simulated transaction ... Read more

Glencore Australia sold copper concentrate to its Swiss parent under a price-sharing agreement. The Australian Tax Office challenged the pricing as below arm's length. After rulings in Glencore's favour at Federal Court and Full Federal Court level, the tax authority sought special leave to appeal. Australia's High Court dismissed the application in May 2021, confirming the outcome in the taxpayer's favour ... Read more

Glencore Australia sold copper concentrate to its Swiss parent under a price-sharing agreement. The Australian tax authority assessed additional income of over $240 million across 2007–2009, arguing prices were below arm's length. The Full Federal Court of Australia dismissed the ATO's appeal in November 2020, upholding the original Federal Court finding that prices paid were within an arm's length range ... Read more

Glencore Australia sold copper concentrate to its Swiss parent, Glencore International AG, under a price-sharing agreement. The Australian Tax Office assessed additional income of over $240 million across 2007–2009, arguing prices were below arm's length. The Federal Court of Australia ruled in favour of Glencore in September 2019, finding the prices paid fell within an arm's length range and setting aside the amended assessments ... Read more

A Finnish construction industry group used the CUP method for intercompany licence fees and the resale price method for product sales during 2006–2008. Tax authorities rejected both methods as unreliable and applied the residual profit split method using 2010 OECD Guidelines. The Supreme Administrative Court held that the OECD Guidelines version current at the time of filing was the correct reference, ruling mostly in favour of the taxpayer ... Read more

A Swedish company sold trademarks for SEK 103 million, but the Swedish Tax Agency argued an arm's length price was SEK 134 million, incorporating tax effects into the valuation. The company contested the inclusion of tax benefits and challenged use of the Gordon growth model. The Administrative Court of Appeal, ruling in 2015, sided with the tax authority, confirming that tax implications for both buyer and seller are relevant when valuing intangible assets ... Read more