Portuguese Court’s decision in transfer pricing dispute relating to inter-company loan and management fees

27 February, 2013

The arbitration administrative court in Portugal recently ruled in favour of the taxpayer in a dispute with the Portuguese Tax Authorities (TA) in respect to the application of the arm’s length principle to inter-company loan and management fee

See More

Authorities’ use of net-back approach in transfer pricing case has been overruled by the Russian Court

15 July, 2011

The Federal Arbitration Court of the Moscow Region rejected the Russian Tax Authorities’ attempt to adjust a taxpayer’s transfer pricing by applying the net-back approach. The net-back method are applied to oil production and operates by taking

See More