Amadeus Global Travel Distribution Limited is a Tanzanian branch of a Kenya-resident entity, itself a wholly owned subsidiary of Amadeus ITG based in Madrid, Spain. The appellant's business consists of commercialising the Amadeus GDS system in Tanzania. The dispute concerned the income year 2015 and ... Read more

Cargill Bulgaria sold wheat, corn, and other agricultural goods to related Cargill entities in Switzerland and the Netherlands. The Bulgarian tax authority applied TNMM using a return-on-sales profit level indicator, benchmarking against five comparables with an interquartile range of 1.21–1.79%, and assessed additional corporate tax exceeding one million leva. Bulgaria's Supreme Administrative Court ruled in favour of the tax authority and remanded the case for re-examination ... 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

A Dutch company operating a long-term modular bridge project abroad disputed the tax authority's reduction of its object exemption for 2018–2020. The authority favoured TNMM and treated the permanent establishment as a routine contributor, but Rechtbank Noord-Holland found the PE's role essential and integrated, upholding the profit split method and rejecting the reversal of the burden of proof ... Read more

The European Commission closed its formal State aid investigation into a Luxembourg tax ruling granted to Amazon in 2003, concluding it did not constitute State aid under Article 107(1) TFEU. The ruling had approved a TNMM-based royalty arrangement allocating profits between Luxembourg entities. Following annulment of the Commission's earlier negative decision by the Court of Justice in December 2023, the Commission adopted this closing decision in November 2024, published in November 2025 ... Read more

Coca-Cola Vietnam's intragroup purchases of concentrate from related parties produced profits below the arm's length interquartile range established by the company's own benchmarking study. The Vietnamese tax authority applied the company's own comparables to restate taxable profits for multiple years between 2007 and 2015, raising an assessment of approximately VND 362 billion. The court upheld the assessment in November 2025, with the Ministry of Finance issuing an official statement on the outcome ... Read more

A Colombian manufacturer within the GKN group made a comparability adjustment in its transfer pricing study to account for the first year of IFRS implementation in 2015. The tax authority rejected the adjustment, determined profitability fell outside the interquartile range, and adjusted results to the median, disallowing deductions. The Supreme Administrative Court ruled in favour of the taxpayer in 2025, accepting the IFRS transition adjustment as valid ... Read more

Shell India Markets Private Limited was assessed by Indian tax authorities, who applied mark-ups to upstream technical services priced at cost under Production Sharing Contracts and disallowed certain downstream cost allocations. The Income Tax Appellate Tribunal ruled in favour of the taxpayer in November 2025, accepting that sovereign contractual restrictions prohibited profit mark-ups and that the cost-based pricing was arm's length ... Read more

Bulgaria's Supreme Administrative Court ruled in November 2025 in favour of the tax authority, confirming transfer pricing adjustments applied to Lukoil Bulgaria. Authorities found wholesale fuel prices paid to Lukoil Neftohim Burgas were above market levels based on EBIT margin analysis, and that the interest rate on a USD 150 million intra-group loan was not arm's length due to undisclosed guarantees, treating excess charges as hidden profit distributions ... Read more

An Italian luxury watch and jewellery distributor was assessed by the Revenue Agency, which rejected its TNMM net cost plus benchmarking and substituted its own EBIT margin comparables from the AIDA database. The company argued the agency's comparability analysis failed to account for contractual terms, market conditions, and business strategies per OECD guidelines. Italy's Supreme Court ruled in favour of the taxpayer in November 2025 ... Read more

A Spanish subsidiary of a multinational consumer goods group was audited for 2015–17 over contract manufacturing services, intra-group loans, and cash pooling arrangements. The tax authority rejected part of the taxpayer's comparable set and adjusted margins to the median, also applying group credit ratings and substituting Euribor with Eonia. Spain's TEAC largely upheld the authority's position in its October 2025 ruling ... Read more

Netflix Entertainment Services India LLP, the Indian subsidiary of Netflix, was characterised by tax authorities as an entrepreneurial licensee rather than a limited risk distributor, with its distribution fee recast as royalty. The Income Tax Appellate Tribunal rejected this recharacterisation in 2025, ruling in favour of the taxpayer and upholding the transactional net margin method applied by Netflix India ... Read more

A Korean subsidiary of a Dutch electronics multinational was assessed for excess transfer prices paid to foreign related parties across medical equipment, household appliances, and lighting segments. Tax authorities aggregated maintenance services with product sales and selected comparables based on domestic service businesses. The Korean Supreme Court remanded the case for reexamination in 2025, finding the comparable selection methodology required further review ... Read more

An Italian company receiving intra-group services was assessed for additional taxable income after tax authorities applied TNMM benchmarking and set arm's length profitability at the third quartile. The taxpayer challenged the comparability of selected European companies, citing differences in business models and asset structures, including fleet ownership. The Italian Tax Court ruled in favour of the taxpayer in September 2025, finding the benchmark study fundamentally flawed ... Read more

A Romanian subsidiary of a Belgian parent received invoices under a transfer pricing agreement to align profits within an agreed margin. Romanian tax authorities disallowed CIT and VAT deductions, citing insufficient proof of services rendered. The Romanian Court of Appeal referred questions to the European Court of Justice, which issued a preliminary ruling in 2025 on whether such year-end adjustments constitute taxable supplies under the EU VAT Directive ... Read more

Medtronic applied the comparable uncontrolled transaction method to set royalty rates between its US parent and Puerto Rico manufacturing subsidiary for use of intangible property. The IRS challenged the allocation, arguing too much profit remained offshore. After Tax Court proceedings and a prior 2018 remand, the US Court of Appeals in 2025 ruled mostly in favour of the tax authority, rejecting Medtronic's CUT method application ... Read more

A Panamanian air freight logistics company applied TNMM with return on total costs for its 2015 intercompany transactions. Tax authorities rejected eight of nine comparables and recalculated results using a single comparable, producing a near-zero margin. Panama's Administrative Tax Court ruled in favour of the taxpayer in August 2025, finding the original comparable set sufficiently reliable and the authority's benchmark methodology flawed ... Read more

Nestlé Zambia Limited recorded continuous losses, prompting the Zambia Revenue Authority to issue a transfer pricing assessment. The Tax Appeals Tribunal had invalidated the assessment over unsuitable comparables and methods. On appeal, the Zambia Supreme Court ruled in 2025 that the burden of proof rests with the taxpayer to disprove assessments, deciding largely in favour of the ZRA while addressing comparability and distributor classification issues ... Read more

Sony India faced transfer pricing adjustments across multiple assessment years covering AMP expenses, royalty payments, and advisory services. India's Income Tax Appellate Tribunal held that neither the Bright Line Test nor intensity adjustments are permissible benchmarking methods under the Income Tax Act, deleting both AMP and royalty adjustments. The Tribunal also directed revisions to the comparables set for advisory services, deciding the case mostly in Sony's favour ... Read more

A Polish company specialising in e-grocery logistics was assessed for additional taxable income after tax authorities applied the transactional net margin method and challenged its intra-group service pricing. The Tax Administration Chamber and Administrative Court annulled the assessment over inappropriate comparables. The Supreme Administrative Court, ruling in August 2025, rejected limitation arguments but remanded the case, finding the lower court had insufficiently examined the transfer pricing methodology and comparability analysis ... Read more

A German importer declared customs values for goods purchased from related foreign entities under a distribution agreement targeting an arm's length return on sales. Following a customs audit, the tax authority challenged the declared values, arguing year-end debit adjustments should increase the customs value. The Bundesfinanzhof decided in favour of the customs authority in July 2025, confirming that transfer pricing year-end adjustments affect dutiable customs value ... Read more

A Panamanian insurance company faced a transfer pricing reassessment after tax authorities rejected its chosen profit level indicator and comparable for excess loss reinsurance premiums ceded to a related party in 2018, issuing additional income and supplementary tax charges. The Administrative Court did not rule on the substantive transfer pricing issues, instead annulling the assessment in 2025 due to serious procedural defects that violated the taxpayer's due process rights ... Read more

A Romanian subsidiary faced a transfer pricing audit covering management fees paid to its foreign parent and affiliated product purchases. The tax authority denied deductions on the services, finding no proven benefit, and rejected the CUP method in favour of a return-on-total-costs adjustment. Romania's Supreme Administrative Court in 2025 largely sided with the taxpayer, partly overturning the administration's adjustments while confirming the disallowance of inadequately evidenced management service fees ... Read more

Hitachi Solutions India excluded goodwill amortisation from operating costs in its transfer pricing comparability study, treating it as a non-operating capital item. The Indian tax authority included it, reducing the profit level indicator. The Chennai Income Tax Appellate Tribunal ruled in the taxpayer's favour in 2025, holding that goodwill amortisation arises from a capital transaction and must be excluded from operating expenses to preserve comparability under the transactional net margin method ... 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

Cipla Kenya Limited, a pharmaceutical distributor, reported an operating margin within the interquartile range under TNMM. The Kenya Revenue Authority adjusted the result to the median, citing comparability defects in the benchmarking study. The Tax Appeal Tribunal sided with the taxpayer in 2025, finding that where defects are explicitly identified, the authority must quantify adjustments rather than default to the median ... Read more

A Korean limited risk distributor importing and selling vehicles incurred substantial losses between 2017 and 2021 following a regulatory sales suspension, undertaking market penetration measures funded partly by parent reimbursements. The tax authority disputed the treatment of those compensations as non-operating income. The National Tax Tribunal upheld the authority's position in 2025, ruling that a limited risk distributor cannot bear market penetration costs and that parent reimbursements must be classified as operating income under the TNMM ... Read more

A Colombian emerald producer used the CUP method to justify related-party sales prices, relying on independent appraiser valuations as comparables. The tax authority rejected this approach and applied TNMM using a cost-based profit level indicator, adjusting income to the benchmarking median. The Council of State upheld the assessment in April 2025, confirming that appraiser valuations do not constitute comparable uncontrolled prices under the CUP method ... Read more

A Romanian subsidiary of Arcomet Belgium received invoices under a transfer pricing agreement designed to keep profits within an agreed TNMM margin. Romanian tax authorities denied corporate tax and VAT deductions, citing lack of proof of service necessity. The Romanian Court of Appeal referred questions to the ECJ, prompting a 2025 Advocate General opinion on whether such year-end adjustments constitute taxable supplies under EU VAT rules ... Read more

A Slovak company submitted transfer pricing documentation relying on a full-range benchmark, but tax authorities found 9 of 10 comparables lacked independence. The authorities conducted their own TNMM benchmark, concluded the controlled transactions fell outside the interquartile range, and adjusted pricing to the median. The Administrative Court dismissed the taxpayer's appeal in March 2025, upholding the assessment in full ... Read more

A Romanian company challenged additional corporate income tax following transfer pricing adjustments for FY 2012–2017. The Bucharest Court of Appeal had largely upheld the tax authority's position for FY 2013–2017. Romania's Supreme Administrative Court quashed that decision in 2025, finding the lower court had reproduced the tax authority's reasoning without independent analysis and failed to justify its rejection of the court-appointed expert's findings, remanding the case for fresh review ... 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

AON Consulting priced its US-related-party transactions under a US-India Mutual Agreement Procedure. The Indian tax authority sought to apply the same MAP framework to non-US controlled transactions. The Delhi High Court set aside the ITAT ruling, holding that a MAP agreement between two contracting states cannot substitute the statutory arm's length price determination under Section 92C for transactions outside the MAP's scope ... Read more

A Polish ERP software distributor made year-end licence fee adjustments under a group agreement to maintain an arm's length operating margin. The tax authority treated compensation payments received as VAT-liable services. The Supreme Administrative Court dismissed the authority's appeal in February 2025, confirming that such payments did not constitute remuneration for a specific service and were not subject to VAT ... Read more

The Italian Revenue Agency challenged transfer pricing arrangements involving Kulch S.p.A. and Eco Leather S.p.A., arguing the Regional Tax Commission wrongly rejected the TNMM in favour of the CUP method. Italy's Supreme Court dismissed the Agency's appeal in January 2025, confirming that CUP was the most appropriate method, that no interest was owed by the American subsidiary, and that commissions paid to a Hong Kong entity were legitimately deductible ... Read more

A Ukrainian wallpaper manufacturer challenged tax assessments covering FY 2013–2015, where authorities insisted only partial-year data should be used to calculate TNMM profit level indicators for controlled transaction periods. The company argued full-year figures were appropriate given the seasonal nature of wallpaper demand and the limitations of comparables databases. Ukraine's Supreme Administrative Court ruled in favour of the taxpayer in January 2025, confirming that annual financial data was the correct basis for the benchmarking analysis ... Read more

A Panamanian electronics distributor purchased all goods from related parties abroad and sold primarily to foreign customers in 2014. Tax authorities rejected the Resale Price Method, applied TNMM, and issued a supplementary assessment of approximately B/.546,700. The Administrative Court ruled in 2025 that Panama's transfer pricing regime could not apply to income exempt from corporate income tax, revoking the assessment and cancelling all surcharges in full ... Read more

A Spanish tyre distributor claimed its intra-group purchases from its German parent used the CUP method, arguing prices matched third-party supplier rates. The tax authority rejected this, applying TNMM with EU car parts wholesaler comparables and adjusting profits to the median. The Audiencia Nacional in 2024 largely upheld the tax authority, finding the CUP application inconsistent and approving the TNMM benchmark, while partially allowing the taxpayer's appeal ... Read more

A Paris luxury shoe retailer operating under the Roger Vivier brand had generated negative net margins since 2003. French tax authorities challenged low resale prices on unsold goods and excessive brand promotion costs as indirect profit transfers, applying a 6.76% average operating margin benchmark. The Paris Administrative Court of Appeal upheld the adjustments in December 2024, ruling in favour of the tax authority ... Read more

Argentina's tax authority AFIP excluded R&D, advertising, and commercial costs from comparable companies' financials in Nestlé's TNMM transfer pricing analysis for FY 2009, inflating their margins and increasing Nestlé's taxable income. The Supreme Court found the appellate court had arbitrarily failed to engage with Nestlé's core arguments, violating its constitutional right to defence, and annulled the lower court decision, remanding the case for reconsideration ... Read more

A Japanese conglomerate was assessed by tax authorities who applied a method they claimed was equivalent to the Transactional Net Margin Method to price transactions involving turbocharger parts and licences with a Thai affiliate. The taxpayer argued the method was not a valid TNMM equivalent. The Tokyo High Court upheld the 2023 Tokyo District Court ruling, deciding in favour of the taxpayer and rejecting the tax authority's assessment ... Read more

A Greek elevator company used TNMM for related-party sales, but the tax authority substituted a cost plus method using internal third-party comparables, raising taxable income. The Administrative Court largely upheld the authority's approach in 2024, finding internal comparables reliable after adjustments. However, it annulled the adjustment for sales to a Turkish affiliate, ruling that market differences and a market-penetration strategy made those sales incomparable to Swedish or Czech transactions ... Read more

Colombia's Supreme Administrative Court ruled mostly in favour of ABB Ltda in a dispute over the tax authority's rejection of five comparables from a TNMM benchmark study. The court reinstated four of the five excluded companies, finding insufficient grounds for their removal, and only upheld the exclusion of Dulhunty Power Ltd. due to significant intangibles. Recalculating the interquartile range, the court confirmed that the taxpayer's transactions fell within the arm's length range and restored the disallowed expenses ... Read more

A Swiss pharmaceutical company, restructured as a limited risk distributor following acquisition by a Canadian group, reported a -21.8% operating margin in 2018 while claiming a three-year average of 1.2% satisfied arm's length requirements. The tax authority adjusted the 2018 margin to 1.1%, adding CHF 8.9 million to taxable profit. Switzerland's Administrative Court upheld the adjustment in 2024, ruling that Swiss periodicity principles require annual profit assessment and rejecting retrospective multi-year margin smoothing ... Read more

A Kenyan assembler of Chinese motor vehicle parts applied the resale price method to price intra-group purchases. The Kenya Revenue Authority rejected this approach, applying TNMM and assessing additional income plus withholding tax on a deemed dividend. The Tax Appeals Tribunal upheld the switch to TNMM in 2024 but reduced the withholding tax liability, finding no legal basis for part of the assessed period ... Read more

A Polish bedding textiles producer sold goods to a related party at a return on total costs of 1.61%, below the arm's length interquartile range of 4.20%–9.22% established by the tax authorities' benchmark study. The authorities adjusted profits to the median of 5.23%. In November 2024, the Polish Administrative Court upheld the transfer pricing adjustment, confirming the TNMM as the most appropriate method and the validity of the benchmark analysis ... Read more

JCB India Ltd challenged a ₹166 crore transfer pricing adjustment on royalty payments to associated enterprises for AY 2017–18, arguing that MAP settlements and a subsequent APA should govern the arm's length rate. India's Income Tax Appellate Tribunal found that neither the MAP nor the APA covered the relevant assessment year or non-UK entities, and remanded the matter to tax authorities for fresh determination of the arm's length royalty rate ... Read more

Sabic India, an intra-group marketing services provider, used TNMM with a Berry ratio and cost-based profit level indicators to price controlled transactions. The tax authority rejected the method without reasons and applied an alternative other method. The Income Tax Appellate Tribunal overturned the assessment, and the Delhi High Court upheld that decision in 2024, finding the TPO had failed to justify rejecting TNMM used in prior years ... Read more

An Italian packaging machine manufacturer applied the CUP method to its intra-group transactions, but tax authorities substituted the TNMM following an audit of FY 2008. The Italian Supreme Court dismissed the company's appeal in October 2024, confirming that OECD Transfer Pricing Guidelines are non-binding guidance and that the TNMM was the most appropriate method given the company's limited-risk, pre-confirmed-order manufacturing profile ... Read more

A Slovak contract manufacturer within the Valeo group was subject to a transfer pricing adjustment by the tax authorities, who applied TNMM with an interquartile range and median benchmark and disallowed deductions for intra-group management and technical service fees. The Administrative Court rejected the company's appeal, and the Supreme Administrative Court dismissed the further appeal in September 2024, fully upholding the tax authority's assessment ... Read more