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Transfer Pricing Case Law around the World 2026


ISBN13: 9789403501475
To be Published: September 2026
Publisher: Kluwer Law International
Country of Publication: Netherlands
Format: Hardback
Price: £186.00





Transfer Pricing Case Law Around the World 2026 is a book providing a detailed overview of significant transfer pricing case law and is based on presentations and discussions held during a 2025 symposium organized by the WU Transfer Pricing Centre at the Institute of Austrian and International Tax Law at WU (Vienna University of Economics and Business). The transfer pricing (TP) landscape continues to undergo notable transformation, driven by global developments in the digital economy, an expanding cross-border regulatory and compliance environment, shifts in multinational business models, and the continuous evolution of domestic and international legal practice in the area. Accordingly, transfer pricing litigation has become both more global and increasingly complex.

What’s in this book:

The following themes are covered:

  • accurate delineation
  • comparability analysis
  • the most appropriate method
  • TP documentation
  • intangibles
  • financing, and
  • business restructuring

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. Through a rigorous examination of case law trends, the contributors collectively highlight key developments, challenges, and emerging issues in transfer pricing jurisprudence worldwide.

How this will help you:

With its evidence of a growing cross-border judicial influence contributing to a more harmonized interpretation of global transfer pricing rules, this important book will serve as an invaluable resource for tax lawyers, in-house counsel, judges, academics, and tax authorities – as well as the business community and government officials – providing an opportunity to leverage global judicial trends in strengthening arguments during transfer pricing disputes and applying actionable insights to transfer pricing risks and legal certainty.

Subjects:
Taxation
Contents:
List of Figures
List of Tables
Preface

CHAPTER 1 Introduction
Prisca Eleanor Musibi & Gangshan Cao

Part I TP and Accurate Delineation
CHAPTER 2 Chile v. CAPITARIA S.A.
Cristóbal Pérez Jarpa
CHAPTER 3 Futaba Czech, s.r.o. v. The Appellate Financial Directorate
Karel Brychta &Veronika Solilová
CHAPTER 4 Sweden Swedish Tax Agency Versus Meda AB
Mattias Dahlberg

Part II TP and Comparability Analysis
CHAPTER 5 ABB Ltda. v. Colombian Tax Administration
Eleonora Lozano-Rodríguez & Lorenzo Rodríguez-Albán
CHAPTER 6 Italy v. UFI Filters
Guglielmo Maisto

Part III TP and Most Appropriate Method
CHAPTER 7 Alcoa of Australia Ltd v. Commissioner of Taxation
Fei Gao & Richard Krever
CHAPTER 8 Tax Administration of the Canton of Graubünden v. Kraftwerke A. AG
René Matteotti & Anastasia Antonova
CHAPTER 9 Italy v. Kulch and Eco Leather
Gianluigi Bizioli
CHAPTER 10 Unilever de Centroamérica, S.A. v. Large Taxpayers Central Office
José Manuel Almudí Cid

Part IV TP and Documentation
CHAPTER 11 The Danish Ministry of Taxation v. Accenture A/S
Susi Baerentzen
CHAPTER 12 Hungary v. Hungarian Auto-Electronics Kft
Gabriella Erdos
CHAPTER 13 The Danish Ministry of Taxation v. Viking Life-Saving Equipment A/S
Susi Baerentzen

Part V TP and Intangibles
CHAPTER 14 ABD Limited v. Commissioner for South African Revenue Service
Graeme Saggers & Tracy Johnson
CHAPTER 15 Facebook, Inc. v. Commissioner, US Tax Court Airbnb, Inc. v. Commissioner
Shay Menuchin & Yariv Brauner
CHAPTER 16 Principal Commissioner of Income Tax-8 v. Samsung India Electronics Pvt. Ltd.
Siddhesh Rao

Part VI TP and Financing
CHAPTER 17 Poland v. D. sp. z o.o.
Karolina Tetlak
CHAPTER 18 Kwik-Fit Group Limited and Others v. HMRC
Richard Collier & John Vella
CHAPTER 19 Australian v. Singapore Telecom Australia Investments Pty Ltd
Michael Kobetsky

Part VII TP and Business Restructurings
CHAPTER 20 Netherlands v. Agri B.V.
Frank P.G. Pötgens
CHAPTER 21 Poland v. A Pharma S.A.
Karolina Tetlak
CHAPTER 22 Swedish Tax Agency v. Twilio Sweden AB
Mattias Dahlberg

Index