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 an additional tax return in respect of its 2007 tax liability. In that return, the plaintiff declared that its tax liability for 2007 should have been higher than originally declared, because the transfer prices in transactions with its parent...