French luxury goods manufacturer S.T. Dupont lost an appeal against a transfer pricing adjustment involving a Hong Kong subsidiary, under a ruling of France’s Conseil d’État.
The Wednesday ruling does not disclose the size of the adjustment, only that it relates to the company’s financial years ending in 2009, 2010, and 2011.
According to the court, the company failed to sufficiently explain the “persistent” losses it suffered in France while its fully owned Hong Kong distributor was profitable.
The company argued that the tax authorities failed to account for geographical market differences in their tax review and wrongly compared the ...
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