Although Member States Are Free to Determine their Tax Systems, they Must still Conform with State Aid Rules
Introduction On 10 September 2024, the Court of Justice [CJEU] delivered its much anticipated judgment, […]
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The Consequence of the Tax Autonomy of Member States
Introduction The favourable tax treatment of multinational companies has long been in the sights of […]
The “Arm’s Length Principle” and the Taxation of Transactions between Related Companies
The arm’s length principle is not an autonomous principle that can be applied to any […]
It is Difficult to Challenge a Commission Decision Opening the Formal Investigation Procedure
The assessment of the Commission in an “opening decision” is only provisional. The Commission is […]
Amazon and the Difficulty of Finding a Comparable Tax Payer
To apply the Arm’s Length Principle to transactions between two related companies, the Commission must […]
Taxation of Multinational Companies: The Apple Case – A Political Setback for the Commission, but a Victory on Principle
Defects, incompleteness and inconsistencies in tax rulings are not sufficient to prove the existence of […]