Swedish Court rules on adoption of full-range, multiple year data for comparability analysis

Sep 05,2019

Swedish Supreme Administrative Court (‘the Court’) rules on adoption of full range of results and use of multiple year data in benchmarking analysis of sale transactions by assessee (Swedish company manufacturing, distributing and marketing wine and spirits) to its US-based AE (tested party); Notes that Swedish tax authorities concluded that the prices paid by the US-subsidiary (AE) were lower than ALP based on AE’s TP documentation which stated that it had not paid ...


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