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IOTA Case Study Workshop on Transfer Pricing Issues

On November 5-6, 2025, IOTA successfully organised its final in-person technical event of the year: the Case Study Workshop on Transfer Pricing Issues. Held in Budapest, Hungary, the Workshop brought together 38 tax officials from across 24 IOTA member tax administrations, focusing on the complexities of transfer pricing transactions across various sectors.

This two-day event provided an in-depth exploration of real-life case studies from IOTA members in France, Germany, Romania, and Spain. The discussions centered on how tax authorities approach complex controlled transactions —including different types of transactions from various sectors— aimed to identify common challenges and practical solutions to enhance tax efficiency and ensure taxpayer certainty.

The first day of the event featured insightful presentations by Romeo Filip Stanca & Bianca Bleau from Romania, as well as Pablo Moya from Spain, highlighting approaches to controlling transactions such as managing limited-risk distributors with ongoing losses, Cost Contribution Arrangements (CCAs), and identifying areas for improvement. The second day continued to deepen understanding with case studies from France and Germany, presented by Catherine Dewavrin & Bertrand Briet, and Tobias Mönch. These discussions addressed key issues including group restructuring, the transfer of intellectual property, and shifting the cost base.

The event aimed to foster international collaboration, improve solutions, and provide clearer guidance for stakeholders involved in transfer pricing. All event materials and a photo gallery are now available on the IOTA web portal. This workshop was facilitated by IOTA International Taxation Expert Alexandros Roukalis, with support from his colleague Ivana Donchevska.

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