22 November 2024 Kenya’s Tax Appeals Tribunal reviewed whether Avic International Beijing (EA) Limited correctly used the resale price method to price purchases of completely knocked-down motor vehicle kits from its Chinese affiliate. The taxpayer argued that the RPM was appropriate, but the tax authority applied the transactional net margin method, leading to additional taxable income and a deemed dividend subject to withholding tax. The Tribunal upheld the use of the TNMM,

27 May 2025 Germany’s Constitutional Court examined whether Section 1 of the Foreign Tax Act was constitutionally applied in a dispute involving Timber GmbH & Co. KG. The taxpayer challenged profit adjustments made by the tax authority, arguing that the use of OECD-aligned methods exceeded administrative discretion. The Court disagreed, holding that the comparable profits and resale price methods were appropriate tools for assessing the arm’s length nature of the company’s

December 2020 Taiwan’s Supreme Administrative Court reviewed a dispute concerning Weitian Technology’s pricing of contract manufacturing services for a foreign affiliate. Tax authorities applied the Cost-Plus Method, asserting that Weitian’s margins fell below independent benchmarks. Although the taxpayer argued that the TNMM was more appropriate due to functional differences, the Court held that Cost-Plus better reflected the economic reality of its limited-risk manufacturin

October 1, 2025 The U.S. Court of Appeals revisited disputes over the valuation of intangible property transferred to foreign affiliates under a cost-sharing arrangement. The IRS contended that 3M understated the value of its intangibles, failing to meet the “commensurate with income” standard of IRC Section 482. The Court upheld the IRS’s income-based valuation, recognizing the use of post-transaction profit evidence to test arm’s length results. By endorsing the IRS’s appro

May 2023 The Swiss Federal Administrative Court assessed the deductibility of intercompany service fees and management charges between two related entities. The Swiss tax authority argued the charges lacked commercial justification and duplicated group-wide services, asserting they failed the arm’s length principle. The Court agreed, concluding the taxpayer did not sufficiently prove measurable benefits arising from the services rendered. By affirming the tax authority’s posi

May 5, 2025 The Federal High Court reviewed the legality of penalties imposed under Nigeria’s Country-by-Country Reporting (CbCR) regime,...

Date: 6 February 2025 The Delhi High Court recently ruled in AON Consulting Pvt. Ltd. v. Principal Commissioner of Income Tax on a key...

19 March 2025 The Polish Supreme Administrative Court addressed a dispute involving the tax treatment of trademark royalties received...

June 2025 In a landmark transfer pricing case, the Reykjavík District Court ruled in favor of the Icelandic tax authority, raising...

February 13, 2025 The U.S. District Court for the Western District of Tennessee has ruled in favor of FedEx Corp in a significant...