Reference : Transfer pricing rules and State aid law
Parts of books : Contribution to collective works
Law, criminology & political science : Tax law
Law, criminology & political science : European & international law
Law / European Law
Transfer pricing rules and State aid law
Haslehner, Werner mailto [University of Luxembourg > Faculty of Law, Economics and Finance (FDEF) > Law Research Unit >]
Research Handbook European Union Taxation Law
Panayi, Christiana HJI
Haslehner, Werner mailto
Traversa, Edoardo
Edward Elgar
United Kingdom
[en] State aid ; arm's length standard ; transfer pricing ; tax rulings ; double taxation ; double taxation treaties ; administrative discretion
[en] This contribution addresses the interaction of State aid law with transfer pricing rules. A number of high-profile investigations into transfer pricing arrangements approved by Member States’ authorities, including for companies like Amazon, Apple, and Starbucks has sparked fierce debate over the existence of an EU principle of “arm’s length” taxation and its possible content. The chapter examines this debate and issues pertaining to the relationship between State aid law and double taxation treaties, justifications on the basis of providing double tax relief or protection from tax avoidance, and the scope of administrative discretion that State aid law needs to accord in a highly technical area of national law such as transfer pricing.
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