Czech Auto Supplier Wins Transfer Pricing Adjustment Tax Case

June 15, 2023, 3:01 PM UTC

The Czech Republic’s Supreme Administrative court confirmed Thursday the dismissal of a transfer pricing adjustment against a Czech automotive supplier now belonging to ERT Têxtil Portugal.

According to the court, the Czech tax authorities made incorrect assumptions in their decision that fees charged in 2013 by ERT Automotive Bohemia to a related company in Germany were too low. Both companies were at the time owned by Notos Beteiligungen GmbH.

The June 15 decision confirms a 2022 lower court ruling canceling a 2.69 million Czech koruna ($123,000) transfer pricing adjustment including penalty interest.

The decision is final, though the door ...

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