When Courts Decide: Transfer Pricing Case Law from 21 Jurisdictions
Transfer pricing is no longer settled only in tax audits and treaty negotiations. More and more, it is settled in court. OECD statistics, reported by International Tax Review in October 2025, show new transfer pricing cases in mutual agreement procedures jumping 29.1% in 2024, with the average case still taking about 31 months to close. When administrative routes stay slow, taxpayers and authorities increasingly turn to the judge, and the rulings pile up in many different languages and legal systems.
A single volume for a scattered body of case law
Transfer Pricing Case Law Around the World 2026, edited by Raffaele Petruzzi and Michael Lang for Kluwer Law International, gathers that scattered material. It grew out of a 2025 symposium at the WU Transfer Pricing Centre in Vienna, and it devotes one chapter to each of 21 landmark decisions, written by specialists from the country concerned. The cases are grouped in seven parts: accurate delineation, comparability analysis, the most appropriate method, documentation, intangibles, financing and business restructurings. The decisions range from Alcoa of Australia and Facebook and Airbnb in the US Tax Court to Samsung India, Kwik-Fit in the UK and Accenture in Denmark.
Where it helps in practice
- Building a dispute strategy. Counsel can see how courts in other jurisdictions reasoned on the same issue and use that as persuasive support.
- Preparing documentation. The documentation chapters show how courts in Denmark and Hungary treated documentation failures and what that means for file preparation.
- Assessing intangibles and financing risk. The intangibles and financing parts show where profit allocation arguments succeeded or failed, which is useful before a group restructures.
For law and tax libraries
For university law libraries, tax institutes and firm libraries, this is a comparative reference that few collections cover. It pairs well with Transfer Pricing and Financing and with our wider Law collection. It is a print-on-demand title, so allow one to three weeks for printing.
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Q&A
Q: Why is transfer pricing case law becoming more important?
A: Administrative dispute resolution is slow, so more disputes reach national courts. Rulings from other countries are increasingly cited as persuasive guidance on how the OECD rules should be read.
Q: What themes does the book cover?
A: Accurate delineation, comparability analysis, the most appropriate method, documentation, intangibles, financing and business restructurings, each illustrated by court decisions.
Q: Which jurisdictions are included?
A: Cases come from Europe, the Americas, Africa, Asia and Australia, including Chile, Colombia, Australia, South Africa, India, Denmark, Poland, the United Kingdom and the United States.
Q: Who is this book for?
A: Tax lawyers, in-house tax counsel, tax authorities, academics and libraries that support international tax research.
Q: Where can I buy Transfer Pricing Case Law Around the World 2026?
A: At clnzbooks.com, with card and PayPal checkout. Worldwide shipping is included in the price.