Czech court gives verdict on methodology
February 23, 2010
A case that has just been decided in the Czech Supreme Administrative Court (SAC) provides an important discussion on transfer pricing methodology in disputes with the tax authorities in the context of the Czech tax law.
In particular, case number 80 Afs 80/2007 – 105 addresses to what extent a range of comparable data should be used to determine an arm’s-length price. Although the case deals with a transaction between individuals and SAC cases are not legal precedents, it is still widely applicable to a number of other taxpayers and corporate transactions.
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