The "Mountfield Case," or Where Tax Optimization Ends and Abuse of Law Begins
TaxesIn judgment 8 Afs 173/2024-121 of August 7, 2026, the Supreme Administrative Court (hereinafter the "SAC") dismissed the cassation appeal filed by Mountfield and upheld the conclusions of the tax administration and the regional court, according to which the company abused the law by establishing a structure related to the early settlement of its liabilities arising from the purchase of trademarks.