Supreme Administrative Court Decision on Intra-Group Services Involving the Stock Spirit Group

This article provides some insights into the methodological approach of the Czech judiciary in the example of the Stock Spirits Group case involving intra-group services, including consulting services remunerated with a feature resembling a profit split method, charges made for support services and the recharge of services from third parties related to the refinancing of the loan. The key issue of dispute was the burden of proof on the taxpayer to establish that the services can be deducted for tax purposes, rather than the specific transfer pricing methodology.