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Preliminärt pris: 2344 SEK exkl. moms  |  Transfer Pricing Case Law Around the World 2025 is a pioneering overview of relevant case law based on papers prepared and discussed by seasoned academics during the 2024 WU Transfer Pricing Symposium organized by the WU Transfer Pricing Centre at the Institute for Austrian and International Tax Law at WU (Vienna University of Economics and Business) on 24 and 25 October 2024. It provides a multi-jurisdictional case law analysis focusing on twenty landmark court cases from fourteen jurisdictions around the world.
What’s in this book:
The book is organized for clarity and ease of reference according to the interaction of transfer pricing rules with the following legal issues:
- burden of proof;
- non-recognition of accurately delineated transactions;
- anti-abuse rules;
- intra-group losses;
- attribution of profits to permanent establishments;
- blocked income; and
- EU State Aid.
A concise explanation of each theme highlights its significance from a transfer pricing perspective and also examines how courts in different jurisdictions have approached and analysed these issues, providing insights into a broad spectrum of legal reasoning and interpretation.
How this will help you:
The case law analysis presented in this significant book elucidates the growing number of transfer pricing disputes arising from differing interpretations of the application of the arm’s length principle among various jurisdictions. The contributors’ rigorous examination of key developments, challenges, and emerging issues in transfer pricing jurisprudence serves as an invaluable resource for tax lawyers, in-house counsel, judges, academics and tax authorities, providing an opportunity to leverage global judicial trends in strengthening arguments during transfer pricing disputes, as well as applying actionable insights to transfer pricing risks and legal certainty. By offering critical insights into judicial reasoning across multiple jurisdictions, the book enables readers to apply actionable strategies for managing transfer pricing risks and enhancing legal certainty.
Table Of Contents
Editors
Assistant Editors
Contributors
Summary of Contents
Preface
CHAPTER 1
Introduction
Part I
TP and the Burden of Proof
CHAPTER 2
Italy v. Dolce and Gabbana S.R.L
CHAPTER 3
The Czech Republic v. ERT Automotive Bohemia s.r.o.
CHAPTER 4
X B.V. v. the Inspector of Taxes (Lux Credit B.V.)
Part II
TP and Non-recognition
CHAPTER 5
Ketua Pengarah Hasil Dalam Negeri v. Watsons Personal Care Stores (M) Holdings Ltd (2023)
CHAPTER 6
Denmark v. Total Energies (Mærsk Olie & Gas)
CHAPTER 7
Luxembourg v. LLC AB
Part III
TP and Anti-abuse Rules
CHAPTER 8
X B.V. v. Staatssecretaris Van Financiën
CHAPTER 9
Portugal v. Sociedade Unipessoal LDA
CHAPTER 10
Skechers USA, Inc. v. Wisconsin Department of Revenue
CHAPTER 11
BlackRock Holdco 5, LLC v. The Commissioners for His Majesty’s Revenue and Customs
Part IV
TP and Intra-group Losses
CHAPTER 12
The Czech Republic v. Stora Enso Wood Products Ždírec s.r.o.
CHAPTER 13
France v. ST Dupont
CHAPTER 14
Argentina v. Dart Sudamericana
Part V
TP and Attribution of Profits to PEs
CHAPTER 15
Compañía Española de Petróleos SA v. Agencia Estatal de Administración Tributaria
CHAPTER 16
Germany v. Z-Pipeline
Part VI
TP and Blocked Income
CHAPTER 17
3M Co. v. Commissioner
CHAPTER 18
Coca-Cola Co. et al. v. Commissioner
CHAPTER 19
Denmark v. EAC Invest A/S
Part VII
TP and EU State Aid
CHAPTER 20
Fiat and Ireland v. Commission
CHAPTER 21
Commission v. Ireland and Others | | |
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