Transfer Pricing Case Law Around the World 2025

Author: Michael Lang; Raffaele Petruzzi
Publisher: Kluwer Law International
ISBN: 9789403513294

Previous Edition ISBN: 9789403526287
Published In: September 2025
Format: Hardback
Jurisdiction: International ? Disclaimer:
Countri(es) stated herein are used as reference only

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Description
Contents

Details

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.

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