Transfer Pricing Case Law Around the World 2026

Raffaele Petruzzi (Editor), Michael Lang (Editor)

ISBN: 9789403501475

Published: October 2026

Format: Hardback

Language: English

Publisher: Kluwer Law International

Description

Transfer Pricing Case Law Around the World 2026 surveys the most significant transfer pricing court decisions from jurisdictions across Europe, the Americas, Africa, Asia and Australia. It grows out of a 2025 symposium organised by the WU Transfer Pricing Centre at the Institute of Austrian and International Tax Law, WU (Vienna University of Economics and Business).

Transfer pricing disputes are becoming more global and more complex, shaped by the digital economy, expanding cross-border compliance requirements and the changing business models of multinational groups. Each chapter takes one landmark decision, explains what it means for transfer pricing practice, and shows how the courts of that country reasoned through the issue.

📖 Why are more transfer pricing disputes ending up in court? Read our blog: When Courts Decide: Transfer Pricing Case Law from 21 Jurisdictions →

Key Features

• Twenty-one case chapters, each examining a landmark transfer pricing decision from a different jurisdiction
• Organised in seven parts: accurate delineation, comparability analysis, most appropriate method, documentation, intangibles, financing and business restructurings
• Includes decisions involving Facebook and Airbnb (US Tax Court), Alcoa of Australia, Samsung India, Kwik-Fit (UK) and Accenture (Denmark)
• Practical value: use cross-border judicial trends to strengthen arguments in a transfer pricing dispute and to assess risk in documentation, intangibles and intra-group financing
• Trend analysis showing growing cross-border judicial influence and a more harmonised reading of global transfer pricing rules

Coverage

Accurate delineation of controlled transactions; comparability analysis; selection of the most appropriate method; transfer pricing documentation; intangibles; intra-group financing; and business restructurings. Practical applications include preparing contemporaneous documentation that withstands court scrutiny, benchmarking positions against how foreign courts treat comparables, and anticipating how tribunals approach restructurings and intangible-related profit allocation.

About the Authors

The volume is edited by Raffaele Petruzzi and Michael Lang. The introduction is by Prisca Eleanor Musibi and Gangshan Cao, and the case chapters are written by tax academics and practitioners from the jurisdictions concerned, including Cristóbal Pérez Jarpa, Guglielmo Maisto, Richard Krever, René Matteotti, José Manuel Almudí Cid, Susi Baerentzen, Graeme Saggers, Yariv Brauner, Karolina Tetlak, Richard Collier, Michael Kobetsky and Mattias Dahlberg.

Table of Contents

List of Figures
List of Tables
Preface
Chapter 1. Introduction (Prisca Eleanor Musibi & Gangshan Cao)

Part I. TP and Accurate Delineation
Chapter 2. Chile v. CAPITARIA S.A. (Cristóbal Pérez Jarpa)
Chapter 3. Futaba Czech, s.r.o. v. The Appellate Financial Directorate (Karel Brychta & Veronika Solilová)
Chapter 4. Sweden: Swedish Tax Agency v. Meda AB (Mattias Dahlberg)

Part II. TP and Comparability Analysis
Chapter 5. ABB Ltda. v. Colombian Tax Administration (Eleonora Lozano-Rodríguez & Lorenzo Rodríguez-Albán)
Chapter 6. Italy v. UFI Filters (Guglielmo Maisto)

Part III. TP and Most Appropriate Method
Chapter 7. Alcoa of Australia Ltd v. Commissioner of Taxation (Fei Gao & Richard Krever)
Chapter 8. Tax Administration of the Canton of Graubünden v. Kraftwerke A. AG (René Matteotti & Anastasia Antonova)
Chapter 9. Italy v. Kulch and Eco Leather (Gianluigi Bizioli)
Chapter 10. Unilever de Centroamérica, S.A. v. Large Taxpayers Central Office (José Manuel Almudí Cid)

Part IV. TP and Documentation
Chapter 11. The Danish Ministry of Taxation v. Accenture A/S (Susi Baerentzen)
Chapter 12. Hungary v. Hungarian Auto-Electronics Kft (Gabriella Erdős)
Chapter 13. The Danish Ministry of Taxation v. Viking Life-Saving Equipment A/S (Susi Baerentzen)

Part V. TP and Intangibles
Chapter 14. ABD Limited v. Commissioner for South African Revenue Service (Graeme Saggers & Tracy Johnson)
Chapter 15. Facebook, Inc. v. Commissioner, US Tax Court; Airbnb, Inc. v. Commissioner (Shay Menuchin & Yariv Brauner)
Chapter 16. Principal Commissioner of Income Tax-8 v. Samsung India Electronics Pvt. Ltd. (Siddhesh Rao)

Part VI. TP and Financing
Chapter 17. Poland v. D. sp. z o.o. (Karolina Tetlak)
Chapter 18. Kwik-Fit Group Limited and Others v. HMRC (Richard Collier & John Vella)
Chapter 19. Australian v. Singapore Telecom Australia Investments Pty Ltd (Michael Kobetsky)

Part VII. TP and Business Restructurings
Chapter 20. Netherlands v. Agri B.V. (Frank P.G. Pötgens)
Chapter 21. Poland v. A Pharma S.A. (Karolina Tetlak)
Chapter 22. Swedish Tax Agency v. Twilio Sweden AB (Mattias Dahlberg)

Index

Why buy this book?

• See how courts in different countries actually decide transfer pricing disputes, not only what the OECD guidance says
• Find precedent from foreign jurisdictions to support or challenge a position in your own case
• Benefit from the WU Transfer Pricing Centre's academic framework, applied by local experts in each case chapter
• A single reference for tax lawyers, in-house counsel and tax authorities facing cross-border transfer pricing risk

Keywords

Transfer Pricing, Case Law, Accurate Delineation, Comparability Analysis, Most Appropriate Method, TP Documentation, Intangibles, Intra-Group Financing, Business Restructuring, International Tax Law

Target Audience

Tax Lawyers, In-House Tax Counsel, Tax Authorities, Academics

Genre

Taxation, International Tax Law, Academic Reference, Professional Reference

Q&A

Q: What does "Transfer Pricing Case Law Around the World 2026" cover?
A: It reviews landmark transfer pricing court decisions from many jurisdictions, grouped by theme: accurate delineation, comparability, method selection, documentation, intangibles, financing and business restructurings.

Q: Where do the cases in this book come from?
A: They come from courts and tribunals in Europe, the Americas, Africa, Asia and Australia, including Chile, Colombia, Australia, South Africa, India, Denmark, Poland, the United Kingdom and the United States.

Q: How do courts treat comparability analysis in transfer pricing disputes?
A: The book contrasts how national courts assess comparables and adjust for differences, using cases such as ABB Ltda. in Colombia and UFI Filters in Italy.

Q: Who should read this book?
A: Tax lawyers, in-house tax counsel, tax authorities and academics who deal with cross-border transfer pricing risk and litigation.

Q: Is this book part of a series?
A: It continues the WU Transfer Pricing Centre's edited volumes from Kluwer Law International, and it follows a 2025 symposium held at WU Vienna.

Q: Where can I buy Transfer Pricing Case Law Around the World 2026?
A: It is available at clnzbooks.com, with card and PayPal checkout and worldwide shipping included in the price. This is a print-on-demand title, so allow 1 to 3 weeks for printing.

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