Our tax litigation team has advised the client in a tax dispute concerning the relationship between transfer pricing rules and the substance over form principle. The Tax Authorities applied the substance over form principle only by arguing that a real estate was acquired from the associated parties for a very high price. Since, according to Lithuanian case law, transfer pricing rules takes precedence over the substance over form principle, our law firm successfully convinced the Tax Authorities to drop the accusations based on the substance over form principle.
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