In the Tokyo High Court judgment, dated 13 May 2015, Honda Motor Company Limited, a major Japanese automobile manufacturer, obtained a cancellation of a tax assessment of Â¥25.4 billion. The court held that the tax authorities had erred in the selection of companies comparable to the tested party (Honda’s foreign subsidiary in Brazil). The tested party was doing business in the Free Economic Zone of Manaus in Brazil – whereas the selected comparables was located outside the zone. The existence of Manaus Tax benefit was considered a market condition affecting the degree of profitability. Hence profits of the Honda subsidiary in Manaus could not be determined based on similar independent Brazilian companies outside the zone and therefore not comparable. Click here for English Translation ...