Tag: Updated transfer pricing documentation

Obligation requiring taxpayers to revise TP documentation when facts or functional characterisations change. Authorities challenge cases where original documentation — such as a limited-risk manufacturer profile — no longer reflects actual conduct, functions, or risks assumed, exposing taxpayers to adjustments.

Czech Republic vs Aisan Industry Czech, s.r.o., April 2022, Supreme Administrative Court, Case No 7 Afs 398/2019 - 49

Czech Republic vs Aisan Industry Czech, s.r.o., April 2022, Supreme Administrative Court, Case No 7 Afs 398/2019 – 49

/ Burden of Proof, Losses, Transfer Pricing Documentation, Transfer Pricing Methods, Aisan, Aisan Industry, Compensating adjustment, Continuous losses, Contract manufacturing, Frequency of documentation updates, Limited risk manufacturing, Losses, No control over risk, Not-identified transactions, Prices determined by group, Shifting burden of proof, Updated transfer pricing documentation
A Czech subsidiary of the Japanese Aisan Industry Group, classified as a limited-risk contract manufacturer, reported operating losses for several years. The tax authority applied the TNMM method and issued a corporate income tax assessment for FY 2011. The Regional Court dismissed the taxpayer's appeal, and the Czech Supreme Administrative Court confirmed that the subsidiary should have been compensated by the group for its manufacturing services ... Read more
Czech Republic vs Aisan Industry Czech, s.r.o., October 2019, Regional Court, Case No 15 Af 105/2015

Czech Republic vs Aisan Industry Czech, s.r.o., October 2019, Regional Court, Case No 15 Af 105/2015

/ Burden of Proof, Losses, Transfer Pricing Documentation, Transfer Pricing Methods, Aisan, Aisan Industry, Compensating adjustment, Continuous losses, Contract manufacturing, Frequency of documentation updates, Limited risk manufacturing, Losses, No control over risk, Not-identified transactions, Prices determined by group, Shifting burden of proof, Updated transfer pricing documentation
Aisan Industry Czech, a limited-risk contract manufacturer within the Japanese Aisan Industry Group, reported continuous operating losses for several years. The Czech tax authority applied the TNMM method and issued an additional corporate income tax assessment for FY 2011. The Regional Court dismissed the company's appeal in 2019, confirming that as a contract manufacturer bearing no significant risk, Aisan Industry Czech should have received arm's length compensation from the group ... Read more