Zepos & Yannopoulos successfully litigated for a multinational pharmaceutical and cosmetics company in a Transfer Pricing case before the Court of Appeals.
More specifically, the Court of Appeals reversed a transfer pricing adjustment by the tax authorities. The Court held that the tax reassessment undergoing judicial review was not permitted as it concerned a taxable period in respect of which it was sufficient to hold an unreserved tax certificate issued by the company’s auditors (this possibility being no longer sufficient). Also, the Court ruled that in transfer pricing cases tax authorities must validly establish the existence of indications of transfer pricing infringements prior to the initiation of tax audits aimed at investigating such alleged infringements.
Our core team consisted of Dimitris Gialouris, partner, and Elina Belouli, senior associate.