The Federal Court of Australia rejected Hilton International Australia Pty Ltd's challenge to the Commissioner of Taxation on 9 September 2026 (Case: Hilton International Australia Pty Ltd v Commissioner of Taxation (No 2) FCA 1325). Justice Younan
The Luxembourg Administrative Court (Cour administrative) issued its decision in case 53194C on 22 July 2026, concerning the application of the arm’s length principle to an intra-group debt restructuring and the deductibility of interest
On 18 November 2021, the Russian Ministry of Finance (MoF) published a Guidance Letter No. 03-03-07/85525 clarifying that a loan is considered a controlled debt for Transfer Pricing (TP) purposes if it is granted to a Russian company by a third
