• NEWS
  • 3 JANUARY 2020

Euro 1.2M transfer pricing penalty annulled in Court

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Elina Filippou

Elina Filippou

Partner

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Elina Belouli

Elina Belouli

Associate

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Dimitris Gialouris

Dimitris Gialouris

Partner

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Our firm successfully represented the Greek subsidiary of a food and beverage group before the Administrative Court of First Instance in a Euro 1.2M transfer pricing dispute. The dispute concerned transfer pricing documentation-related penalties and was governed by the previously applicable market regulation regime of Law 3728/2008. The Court upheld the company’s argument that the penalties provided for in that Law, reaching 10% over the value of the relevant intra-group transactions, were applicable only in the event of failure to document intra-group transactions, not in the event of inaccurate or incomplete documentation. The decision is anticipated to impact similar transfer pricing disputes governed by Law 3728/2008, which are still pending before the administrative courts.

Leading lawyers: Elina Filippou, Dimitris Gialouris and Elina Belouli