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 HMRC, which applied...

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 manufacturer,...

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 were justified by...