Signal

FT Cases

Not just what the courts decided. Our view on what it means.

Cases & notes
45Cases & notes
20Countries
2026
NETHERLANDS

XY Finance

Mirrored terms are not a funding link. Trace the money.

20 Aug 2026
LUXEMBOURG

(AA) S.à r.l. — waste-to-energy

A transfer pricing study is time-stamped — and this one was used against the authority that relied on it.

22 Jul 2026
INDIA

Vodafone Idea

A regulatory ceiling is not a market price. It still beat the officer’s comparable set.

30 Jun 2026
ITALY

NN Europe

Valid economic reasons do not satisfy the transfer pricing rules. They switch them off.

7 May 2026
PORTUGAL

Banco 1 (Portuguese branch)

Transfer pricing corrects the transaction you entered into. It does not invent the one you did not.

6 May 2026
NETHERLANDS

X B.V. (bank JV vehicle)

Every rate matched every other rate to three decimals. That was the evidence, not the defence.

1 May 2026
SLOVAKIA

EURO AGRI

A framework agreement is a promise to lend. The transaction is the drawdown.

30 Apr 2026
SPAIN

Bunge Ibérica

The doctrine has not moved. That it has not moved is the news.

22 Apr 2026
NETHERLANDS

Factoring (Netherlands)

The taxpayer argued that its own receipts were interest. Losing that argument cost it EUR 7.7 million.

22 Apr 2026
UGANDA

ATC Uganda

No cash leaves the borrower when interest rolls up. The withholding tax falls due anyway.

27 Mar 2026
NORWAY

Orlen Upstream Norway

Thin capitalisation cuts both ways. Half a counterfactual is no counterfactual.

26 Mar 2026
LUXEMBOURG

(AA) S.à r.l. — financing branch

The taxpayer won the quantum and lost the principle. Both halves are worth reading.

18 Mar 2026
ITALY

PDM D (Gruppo Statuto)

An upstream loan’s below-market rate stands where the authority brings no credit-specific comparables.

4 Mar 2026
NORWAY

Alcoa Norway

A cheap intra-group rate is no shelter from a thin capitalisation adjustment.

13 Feb 2026
FRANCE

Trema Holding

The rating was accepted. The comparables were not — and one comparable is not a range.

16 Jan 2026
KENYA

Del Monte Kenya

The loan failed on substance and documentation before any arm’s length rate question was reached.

16 Jan 2026
2025
FRANCE

EDF International

A conversion option is worthless when the bondholder already owns the issuer — price it as a plain loan.

17 Dec 2025
TANZANIA

SEACOM

Tanzania re-characterises intercompany payables as a loan, with withholding tax on deemed interest.

28 Nov 2025
SWEDEN

Essity Treasury

Sweden mandates the OECD Authorised Approach to attribute shareholdings and acquisition-loan interest to a PE.

21 Oct 2025
SPAIN

XZ España

Spain's TEAC applies the Supreme Court cash-pool doctrine and rejects an intra-European country-risk premium.

20 Oct 2025
NETHERLANDS

Tobacco group

A group core company already carries the group rating — a parent guarantee adds nothing, and the fee is not deductible.

11 Sep 2025
PORTUGAL

D Group (CAAD)

Four times the authority used the same flawed Bank of Portugal benchmark; four times it lost.

22 Aug 2025
UGANDA

Rwenzori Commodities

Uganda's 30% EBITDA cap applies to gross interest; BEPS Action 4's net approach has no force.

30 Jul 2025
 Confirmed
SPAIN

Bunge Ibérica

Spain's Supreme Court fixes cash-pool rules: symmetrical rates and a group credit rating required.

15 Jul 2025
ARGENTINA

Umicore Argentina

Exchange controls blocked repayment, so the authority called the loans equity — and lost.

10 Jul 2025
 Superseded
SLOVAKIA

Euro Agri

With no comparable available, central-bank sectoral average rates set the benchmark, fixed at inception.

10 Jul 2025
NETHERLANDS

Tobacco group (factoring)

Contemporaneous Dutch documentation defeated the authority's attempt to use a 12-year reassessment window.

27 Jun 2025
BELGIUM

J.F.F.H.

The ING loan taken the same day, same amount, same purpose is your internal CUP.

16 Jun 2025
FRANCE

AXA

A restructuring spread on intercompany debt is not a profit transfer where the maturity extension is genuine.

13 Jun 2025
 Superseded
LUXEMBOURG

Waste-to-energy holding

Accepting a below-arm's-length rate on a distressed intercompany loan without fresh analysis is a hidden capital contribution.

6 Jun 2025
BELGIUM

J.C.I.

The modified CUP survives, but the subordination notch does not — intragroup subordination risk is not what it appears.

6 Jun 2025
ARGENTINA

CTM (Mercosur)

Late repayment alone cannot recharacterise an intercompany loan as equity under the economic-reality principle.

20 May 2025
SLOVAKIA

Coca-Cola HBC

A comparability analysis produced during appeal without taxpayer review is a procedural violation that voids the assessment.

15 May 2025
LUXEMBOURG

Infrastructure holding

Zero-interest shareholder loans funding long-term participations in an undercapitalised entity are hidden equity.

17 Apr 2025
TANZANIA

Vodacom

Withholding tax on intercompany loan interest accrues when it falls due — not when it is paid in cash.

8 Apr 2025
TANZANIA

Diamond Trust Bank

Bad-debt write-offs need documented recovery steps; prudential rules cannot override the ITA's accrual basis.

28 Feb 2025
SPAIN

Nutreco España

Cross-border alone cannot make a loan artificial, but a conduit entity with no economic role loses its deduction.

27 Feb 2025
ITALY

Mezzanove Capital

The interest withholding-tax exemption follows the beneficial owner, not the direct recipient; look-through applies.

20 Feb 2025
AUSTRIA

Health & beauty group

Three loan relationships, one test: when does a group intercompany loan become hidden equity under Austrian law?

20 Feb 2025
SWITZERLAND

Retail group (WHT)

Excessive intercompany interest is a hidden distribution — with personal criminal liability for non-declaration.

3 Feb 2025
INDIA

Cyient

Guarantee fees are computed on the actual guarantee period, and a binding letter of comfort is priced as a guarantee.

6 Jan 2025

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