Top Czech Court Confirms Hitachi Subsidiary’s Tax Adjustment

Nov. 13, 2025, 5:55 PM UTC

A top Czech Republic court upheld a 71.39 million Czech koruna ($3.43 million) tax loss reduction for a subsidiary of Hitachi Ltd. due to lack of compensation for a production line conversion.

The ruling from the country’s Supreme Administrative Court on Wednesday upholds a 2021 transfer pricing adjustment for what is now Astemo Czech and annuls a lower-court decision in favor of the company. It relates to the company’s fiscal year from April 2012 through March 2013.

The manufacturing line conversion—from LCD TVs to automotive components—was decided by the Japanese multinational conglomerate in 2012, and its cost was fully absorbed by ...

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