2025

• 3M (US) (Transfer pricing “blocked income” case; application of Loper Bright)

• Bunge (Spain) (Transfer pricing treatment of cash pooling arrangement) (in Spanish)

• Medtronic (US) (Court of Appeals for Eighth Circuit rejects Tax Court’s use of unspecified transfer pricing method)

• Arcomet Towercranes (ECJ) (Are transfer pricing adjustment payments subject to VAT?)

• Eaton (US) (IRS seeking access to employee performance evaluation records, as part of transfer pricing audit – Court of Appeals for Sixth Circuit)

• Volkswagen AG (India) (notional interest imputed under transfer pricing rules and interest article (Art. 11) in Germany / India double tax treaty)

• Sony (India) – transfer pricing – royalties – advertising, marketing and promotion expenses – service fees – Delhi Income Tax Appellate Tribunal decision

• Compañía de Transmisión del Mercosur (Argentina) (transfer pricing – long-term loans vs. capital contributions – recharacterization) (Administrative Court of Appeal) (in Spanish)

• Axa (France) (transfer pricing – interest on intra-group loan) (Paris Administrative Court of Appeal) (in French)

• Facebook (US) (Tax Court validated 2009 cost sharing temporary regulations and income method; however, Court decided that IRS used incorrect inputs when it applied income method)
  Menarini (France) (transfer pricing – losses) (Supreme Administrative Court decision) (in French)

• P. sp. Z o.o. (Poland) (transfer pricing – cost plus method) (Supreme Administrative Court decision) (in Polish)

• DHL Global Forwarding (Norway) (transfer pricing – persistent losses – service charge) (Court of Appeal decision) (in Norwegian)

• ​EET Group (Denmark) (transfer pricing – limited risk distributor – sufficiency of transfer pricing documentation) (Supreme Court decision) (in Danish)

• Alcoa (Australia) (transfer pricing – transactions with unrelated party / possible bribery: arm’s length price?)

• Cipla (Kenya) (transfer pricing – circumstances in which adjustments should be made to median in interquartile range) (Tribunal decision)

• Kamenitza (Bulgaria) (transfer pricing: trademark purchase) (in Bulgarian)

• Sofia Med (Bulgaria) (transfer pricing: service fees) (in Bulgarian)

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2024

• Yazaki (Bulgaria) (transfer pricing: start-up losses for new projects) (in Bulgarian)

• Volkswagen (Argentina) (transfer pricing: extraordinary gain on loan forgiveness – impact on comparability) (in Spanish)

• Eaton (US) (transfer pricing: IRS succeeds in obtaining foreign employee performance evaluations)

• Siemens (Kenya) (transfer pricing: use of median in interquartile range)

• Engie (France) (transfer pricing; business segmentation) (in French)

• Samsung (India) (transfer pricing; characterisation as contract manufacturer vs. licensed manufacturer)

• Share-based awards TP case (Ireland) (transfer pricing treatment of share-based awards)

• BlackRock (UK) (deductibility of interest expense: transfer pricing and “unallowable purpose” rule)

• ABD Limited (South Africa) (transfer pricing: internal CUP)

• Singapore Telecom (Australia) (transfer pricing: determination of arm's length interest rate on related party vendor finance)

• Checkpoint (Kenya) (transfer pricing: can tax authorities make adjustment to median point in arm's length range?)

• Menarini Diagnostics (France) (can tax authorities use the median in the arm’s length range as the default for a transfer pricing adjustment?)​ (in French)

• Sumitomo Chemicals (France) (can tax authorities use the median in the arm’s length range as the default for a transfer pricing adjustment?) (in French)

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2023

• Maersk (Denmark) (transfer pricing: discretionary assessment and determining price on aggregated basis) (in Danish)

• TP median case (Spain) (should transfer pricing adjustment be made to the median of the arm’s length range?) (in Spanish)

• Medtronic Ventor (Israel) (business restructuring) (in Hebrew)

• SAP Labs (India) (TP litigation: availability of appeals to High Court against ITAT’s decision)

• 3M (US) (validity of “blocked income” transfer pricing regulation) (346 pages!)​​