2026​

• Cargill Bulgaria (Bulgaria) – transfer pricing – intra-group sale of agricultural products (Supreme Administrative Court) (in Bulgarian) (Summary by TP cases in English)

• YOLT Services (Czech Republic) – withholding tax on outbound royalties – exemption under double tax treaty – beneficial ownership (Supreme Administrative Court) (in Czech) (Summary by TP cases in English)

• Bridge BV (Netherlands) – attribution of profits to permanent establishment – application of transfer pricing rules – profit split method (District Court of North Holland) (in Dutch) (Summary by TP cases in English)

• Hitachi Astemo (Czech Republic) (transfer pricing – business restructuring – should company have been compensated for undertaking business restructuring?) (in Czech) (Regional Court decision) (Summary by TP cases in English)

• Electricité de France (France) (transfer pricing – convertible bonds (Supreme Administrative Court) (in French) (Summary by TP cases in English)

• Delmonte (Kenya) (transfer pricing – functional analysis – low risk service provider vs. entrepreneur (Tax Appeal Tribunal decision)) (Summary by TP cases)

• Velcro (Spain) (withholding tax on outbound royalties – EU Interest and Royalties Directive – Spain / Netherlands double tax treaty (in Spanish) (Supreme Court decision) (Summary by TP cases in English)

• Nyota (Tanzania) (transfer pricing – deductibility of intra-group service charges (Court of Appeal decision)) (Summary by TP cases)

• Stellantis (EU) (transfer pricing and VAT – whether transfer pricing adjustment causes VAT liability –  ECJ Advocate General’s opinion) (Summary by TP cases)

• SNA (France) (transfer pricing – related party distributor – whether discounts should be taken into account when performing comparability analysis (Administrative Court of Appeal decision) (in French) (Summary by TP cases in English)

• Coffee Exporters (Tanzania) (transfer pricing – whether unrelated purchaser is an associate for transfer pricing purposes (Court of Appeal decision)) (Summary by TP cases)

• SEACOM (Tanzania) (transfer pricing – characterisation of financing as loan – withholding tax on deemed interest (Court of Appeal decision)) (Summary by TP cases)

• ArcelorMittal (France) (transfer pricing – intragroup royalties (Court of Appeal of Paris)) (in French) (Summary by TP cases in English)

• ​Global Services (Denmark) (transfer pricing – intragroup transfer of intangibles – valuation (Tax Tribunal decision) (in Danish) (Summary by TP cases in English)

• Shell (India) (transfer pricing – production sharing contracts – intragroup services provided “at cost” – cost contribution arrangement (Income Tax Appellate Tribunal decision)) (Summary by TP cases)

• Lukoil (Bulgaria) (transfer pricing – price for intragroup purchase of goods and interest rate on intragroup loan – TNMM and CUP methods (Supreme Administrative Court decision) (in Bulgarian) (Summary by TP cases in English)

• Société Générale (France) (transfer pricing – incurring of costs for benefit of foreign subsidiaries (France Supreme Administrative Court decision)) (in French) (Summary by TP cases in English)

• Aggreko (Tanzania) (transfer pricing – allocation of head office expenses (Court of Appeal decision)) (Summary by TP cases)
   

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2025

• Netflix (India) (Transfer pricing – limited risk distributor or entrepreneur?)

• De Grisogono case #2 (Italy) (transfer pricing – limited risk distributor – application of TNMM (Supreme Court)) (in Italian)

• De Grisogono case #1 (Italy) (transfer pricing – CUP vs. TNMM (Supreme Court)) (in Italian)

• Aufeer Design (Czech Republic) (transfer pricing – deductibility of advertising expenses (Supreme Administrative Court)) (in Czech)

• Vodafone Idea (India) (transfer pricing – CUP method – licensing of brand names – royalties (Income Tax Appellate Tribunal))

• A… SGPS (Portugal) (transfer pricing – sale and licence back of brand name (Supreme Administrative Court decision)) (in Portuguese)

• Eli Lilly (Czech Republic) (transfer pricing – cost-plus service contract – deductibility of costs (Supreme Administrative Court decision)) (in Czech)

• Vinnytsia (Ukraine) (transfer pricing – application of comparable uncontrolled price method (Supreme Administrative Court)) (in Ukrainian)

• H Services (Poland) (transfer pricing – whether year-end adjustments could be recognised as current year transfer pricing adjustments (Administrative Court)) (in Polish)

• 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!)​​