Vietnam gazettes decree updating transfer pricing rules
Vietnam has published Decree No. 255/2026/ND-CP, issued on 30 June 2026, introducing a new framework for tax administration of enterprises engaged in related-party transactions. The Decree sets out the principles, methods and compliance requirements
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Sweden: Court rules in favour of Kubal, overturns transfer pricing-based adjustment
Sweden’s Supreme Administrative Court has ruled in favour of Kubikenborg Aluminium AB (Kubal), overturning a transfer pricing-based adjustment made by the Swedish Tax Agency in a dispute concerning the deductibility of damages arising from an
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Italy: Supreme Court exempts certain gratuitous intragroup guarantees from transfer pricing rules
Italy’s Supreme Court has clarified the circumstances in which domestic transfer pricing rules apply to intragroup transactions, confirming that transactions conducted without consideration may remain outside the scope of transfer pricing where
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EU: Court rules transfer pricing profit adjustments fall outside VAT scope
The Court of Justice of the European Union (CJEU) delivered its judgment on 13 May 2026 in Stellantis Portugal, S.A. v Autoridade Tributária e Aduaneira (Case C-603/24) concerning whether intra-group transfer pricing adjustments are subject to
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Poland: Court rules deferred tax regime doesn’t exempt companies from transfer pricing rules
Poland's Supreme Administrative Court has ruled that companies using the deferred corporate income tax regime must comply with transfer pricing rules, including Local File documentation requirements. This ruling details a judgment from the
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Zambia: Supreme Court rules in ZRA v. Nestlé transfer pricing case
Zambia’s Supreme Court upholds ZRA’s transfer pricing audit on Nestlé Zambia, confirming low-risk distributor status and reinstating a ZMW 13.8 million tax assessment. The Supreme Court of Zambia delivered its decision on transfer pricing in
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Denmark: Supreme Court rules arm’s length pricing need not align with interquartile range
The case examined EET Group's taxable income from 2010 to 2012, focusing on revenue from goods sold to seven sales subsidiaries. Denmark’s Supreme Court issued a ruling on the arm's length pricing of transactions between the Danish EET Group
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Australia: Administrative Review Tribunal rules in favour of Alcoa against ATO in key transfer pricing ruling
This case focused on a major transfer pricing issue, where ATO claimed Alcoa underpriced its alumina sales to Aluminium Bahrain B.S.C. (Alba) from 1993 to 2009, causing a tax shortfall of over AUD 213 million. Australia’s Administrative Review
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India: Tax authority is required to provide justification when rejecting a taxpayer’s chosen transfer pricing method
The Delhi High Court delivered a judgement regarding the tax authority's rejection of SABIC India Pvt. Ltd.'s chosen transfer pricing method, ruling that the tax authority is required to provide justification when rejecting a taxpayer's chosen
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US: IRS issues guidelines on inventory valuation methods
The US Internal Revenue Service (IRS) has released an updated practice unit on inventory valuation methods, specifically addressing the Lower of Cost or Market (LCM) approach. The practice unit's general overview comprises the following: There
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Spain: National Court issues rule on TP adjustment using median of arm’s length range
On 29 July 2023, the Spanish National Court issued a decision that provided clarification on the range of arm's length pricing adjustments applicable. In this case, Ferroli Spain, a Spanish manufacturer specializing in non-electric stoves,
See MoreIndia: Supreme Court decides high courts responsible for adjudicating transfer pricing cases
On 19 April 2023, the Indian Supreme Court published a decision on whether High Courts should hear appeals challenging the findings of the Income Tax Appellate Tribunal on transfer pricing issues. The judgment pertains to cases where appeals
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US: Tax court approves agreement resolving APA cancellation case
On 3 February 2023, the US Tax Court issued a rule approving an agreement between Eaton Corporation and the IRS to adjust Eaton's tax bill for 2005 and 2006 to USD 8.8 million. The proposal stems from lengthy litigation in both the Tax Court and
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Germany: CJEU has issued a decision on sanctions for non-compliance with TP documentation requirements
On 13 October 2022, the Court of Justice of the European Union (CJEU) ruled in case: C-431/21Â on sanctions for non-compliance with transfer pricing (TP) documentation requirements. Under German law, there is a rebuttable presumption that the
See MoreUS: Sixth Circuit affirms taxpayer not liable for penalty upon cancellation of APAs
On 25 August 2022, the U.S. Court of Appeals for the Sixth Circuit affirmed in part and reversed in part a decision of the U.S. tax court regarding the transfer pricing case of Eaton Corp. v. Commissioner. Facts of the case Eaton Corporation
See MoreUS: Tax court issues an opinion regarding transfer pricing method
On 18 August 2022, the U.S. Tax Court issued an opinion on the transfer pricing case of Medtronic, Inc. v. Commissioner, T.C.  Memo 2022-85. Facts of the case Medtronic US is the parent company of a global medical device company that
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French Court of Appeal of Paris clarifies TP rules for cross-border group companies
Recently, the French Court of Appeal of Paris issued a decision in the case of France v. Ferragamo France (No. 20PA0360), in June 2022, explaining the transfer pricing (TP) rules for cross-border group companies. The taxpayer (Ferragamo France),
See MoreCzech Republic: Supreme Court makes a decision of a TP case on related party transaction
Recently, the Supreme Administrative Court (SAC) held in judgment 7 Afs 398/2019 – 49 of a transfer pricing (TP) case that tax administrators may assess additional tax based on overall profitability not just for related-party transactions, but
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