Euro 1.2M transfer pricing penalty annulled in Court

Euro 1.2M transfer pricing penalty annulled in Court

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