OrbitaxSupreme Administrative Court rules on burden of proof and application of transfer pricing methods
|Approved Changes|Czech Republic
On 13 March 2013, the Czech Supreme Administrative Court gave its decision in case 1 Afs 99/2012-52, Goldfein CZ s.r.o. v. Appellate Financial Directorate concerning the burden of proof in transfer pricing disputes and the application of transfer pricing methods.
(a) Facts. Goldfein CZ s.r.o. (the plaintiff) was a company resident in the Czech Republic. In August 2008, the plaintiff filed …
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