A decision of the Spanish National Court was published on 29 July 2023 on the tax authority defaulting to the median of the arm's length range when making transfer pricing adjustments. The case involved a Spanish manufacturer of non-electric stoves, heaters, and domestic heating appliances, Ferroli Spain, which is wholly owned through a Luxembourg holding company by an Italian company, Ferroli SpA. Ferroli Spain also wholly owns a Spanish subsidiary, Cointra Godesia, with which it has formed a tax group for corporate tax purposes. For the year concerned, 2011, the tax group reported a negative profit margin on sales in...