ST Dupont vs. France Transfer Pricing Judgment
ST Dupont, a French luxury manufacturer, contested additional tax assessments and penalties imposed by the French tax authorities for the financial ye…
Category: Tax Dispute Resolution
Sociedade Unipessoal, LDA vs Portugal
This case involves a dispute over the deductibility of financial costs related to loans taken out by the taxpayer (A..., Sociedade Unipessoal, LDA) to…
Germany vs “Z Pipeline”: Transfer Pricing Disputes in Multinational Operations
The FG Düsseldorf judgment of May 12, 2023, revolves around the transfer pricing dispute of a multinational enterprise operating a pipeline network a…
Dart Sudamericana Transfer Pricing Case
The case revolves around the transfer pricing methods used by Dart Sudamericana S.A. for the importation of EPS pellets from related companies. The pr…
Skechers USA Inc. vs. USA
The Wisconsin Tax Appeals Commission ruled in favour of the Wisconsin Department of Revenue, affirming its disallowance of royalty deductions claimed …
3M Company v Commissioner of Internal Revenue: U.S. Transfer Pricing and Foreign Legal Restrictions
The dispute focused on the income tax treatment of intellectual property (IP) transactions between 3M's U.S. subsidiaries and its Brazilian subsidiary…
Nokia vs. India: Permanent Establishment and Profit Attribution Dispute
The case revolved around whether Nokia Solutions and Networks Oy had a Permanent Establishment (PE) in India, and whether profits could be attributed …
Fiat Chrysler Finance Europe and Ireland v Luxembourg: State Aid, Transfer Pricing, and the Arm’s Length Principle
The case involves two appeals by Fiat Chrysler Finance Europe (formerly Fiat Finance and Trade Ltd) and Ireland, challenging the General Court's decis…
Eaton Corporation vs. IRS: Transfer Pricing Dispute
Eaton Corporation, a global manufacturer of electrical and industrial products, faced significant tax disputes with the IRS regarding its transfer pri…
Medtronic vs Commissioner of Inland Revenue
The case of Medtronic, Inc. vs. Commissioner of Internal Revenue revolves around the complex issue of transfer pricing, particularly concerning the ap…