June 2026 An ongoing U.S. case is testing how far the IRS can go in restructuring a multinational's intercompany licence arrangements, and how much weight recent appellate reasoning should carry in that analysis. The case, Amgen Inc. v. Commissioner, concerns the pricing of intercompany licences between the pharmaceutical group's U.S. parent and its Puerto Rican manufacturing affiliate. The IRS argues that the arrangement understated the return owed to the U.S. entity, which

4 March 2026 A recent Italian Supreme Court case examined the burden of proof in transfer pricing disputes involving intra-group financing arrangements. The dispute concerned whether the Italian tax authorities had provided sufficient evidence to support a transfer pricing adjustment to the interest rate applied on a loan between related parties. The tax authorities argued that the interest rate charged did not reflect arm’s length conditions and sought to adjust the financin

September 2025 A recent Swiss transfer pricing case examined whether taxpayers can rely on multi-year margin averaging when assessing compliance with the arm’s length principle. The dispute concerned the use of several years of financial results in a benchmarking analysis, rather than evaluating profitability on a year-by-year basis. The taxpayer argued that multi-year data provides a more reliable measure of economic performance by reducing the impact of temporary market flu

12 September 2025 France’s Digital Services Tax (“GAFA Tax”) controversy concerns whether countries can impose unilateral taxes on large digital companies generating significant revenue from local users, even where those companies have limited physical presence in the jurisdiction. France introduced the tax after concerns that highly digitalized businesses were benefiting from the French market while paying relatively low levels of corporate income tax. The tax applies a 3% l

June 12, 2025 The Zuch v. Commissioner concerns whether the U.S. Tax Court retains jurisdiction over a case when the underlying IRS collection action is no longer active. The taxpayer initiated proceedings under the Collection Due Process (CDP) rules, but during the case, the IRS resolved the liability, effectively removing the basis for the dispute. The case raised the question of whether the Tax Court can continue to hear a matter once there is no ongoing collection activit

11 April 2024 The Arcomet Group case concerns whether transfer pricing (TP) adjustments should be subject to VAT. The Belgian Tax Authorities increased the taxable profits of Arcomet through TP adjustments and argued that these adjustments also constituted payments for services, thereby triggering VAT. The dispute was brought before the Court of Justice of the European Union (CJEU), which ruled that TP adjustments are not automatically subject to VAT . The Court held th

June 20, 2024 The Moore v. United States addressed whether Congress may tax certain corporate earnings attributed to shareholders even when those earnings have not been distributed as cash. The dispute centered on the Mandatory Repatriation Tax introduced by the Tax Cuts and Jobs Act, which required U.S. shareholders of certain foreign corporations to pay tax on accumulated profits held offshore. The taxpayers, Charles and Kathleen Moore, held shares in an Indian company that

5 November 2024 The Court of Appeal of England and Wales examined a dispute between Refinitiv group companies and HM Revenue & Customs concerning the application of diverted profits tax to intra-group service arrangements. HMRC issued significant tax assessments, arguing that profits allocated outside the UK did not reflect the arm’s-length principle. Refinitiv contended that its transfer pricing approach was consistent with an earlier Advance Pricing Agreement agreed with HM

11 July 2024 The High Court of Delhi examined a transfer pricing dispute concerning royalty payments made by Samsung India Electronics Pvt. Ltd. to its Korean parent company under a technology licence agreement. Following a tax audit, the Indian tax authorities disallowed the royalty, characterising Samsung India as a contract manufacturer and concluding that the payments were not at arm’s length. On appeal, Samsung India argued that it operated as a full-fledged licensed

10 December 2025 The Cour administrative d’appel de Paris reviewed a transfer pricing dispute concerning the deductibility of intra-group trademark royalty payments made by ArcelorMittal France. Following a tax audit, the French tax authorities disallowed the royalties, concluding that the taxpayer had not demonstrated that the payments reflected an arm’s-length price or generated a measurable economic benefit. On appeal, ArcelorMittal France argued that the royalties wer