High Court Ruling in the Sandoz Transfer Pricing Matter – TNMM Inclusion of Booked Goodwill When Comparing with Benchmarks?

January 2020, the Danish High Court decided in the Sandoz case. The issue was whether under the TNMM, the exclusion by Sandoz of goodwill amortizations were justified, when comparing its EBIT margins with those of a benchmark study. This article presents an overview and discussion of the case.