Our Tax Controversy & Litigation practice successfully litigated for a healthcare company in a Transfer Pricing case before the Court of Appeals.
The Court examined the scope of legislation imposing fines for procedural infringements in transfer pricing documentation and the principle of retroactivity of more lenient fines. The Court held that legislation imposing administrative fines for infringements of transfer pricing documentation obligations does not extend to the contents of the relevant transfer pricing study. Also, that more lenient fines imposed by virtue of the Code of Tax Procedure for failure to comply with certain transfer pricing reporting obligations apply retroactively, also in periods before the Code’s entry into force. In light of these reasons, the appellate court affirmed the annulment of a €1M penalty initially imposed on the company.
Our core team consisted of partners Elina Filippou and Dimitris Gialouris, and senior associates Elina Belouli and Eva Yotakou.