The EU Joint Transfer Pricing Forum (JTPF) has proposed modifications to the EU Arbitration Convention and revised Code of Conduct to better accommodate transfer pricing disputes. in a report released on its website, the JTPF . . .
The European Commission on Oct. 7 announced that it has opened an in-depth investigation into whether Luxembourg granted private rulings to an Amazon subsidiary with too favorable terms, potentially violating EU rules on state aid.
The 2003 tax ruling, which is still in force, sets a methodology for the payment of a tax deductible royalty by Luxembourg-based Amazon EU Sàrl to a related limited liability. . .
The European Commission today announced that it has determined that advance pricing agreements granted to a Starbucks subsidiary by The Netherlands and to Fiat subsidiary by Luxembourg were illegal state aid because they sanctioned the allocation of too little profit to activities in those countries and . . .
The European Council on October 6 reached unanimous agreement on a directive that would require EU states to automatically exchange information about private tax rulings with other EU states. The agreement, reached at an ECOFIN meeting in Luxembourg, obliges . . .
The European Commission, on June 11, announced that it is investigating whether individual transfer pricing rulings granted to Apple in Ireland, Starbucks in the Netherlands, and Fiat in Luxembourg sanctioned the allocation of too little profit to activities in those countries, thereby amounting to illegal state aid. The Commission has also initiated an infringement action against Luxembourg in connection with the matter.
The decision is part of a wider investigation into whether tax rulings and
. . .
-Update: The Luxembourg Finance Ministry, in a June 12 statement, said it would continue to defend against the Commission’s charges of illegal state aid, and said it still has doubts about the legality Commission requests for information, see statement.
The Netherlands announced November 27 that it will appeal the EU Commission’s October 21 ruling that an advance pricing agreement (APA) granted by the Netherlands to a Starbucks subsidiary amounted to illegal State aid because it sanctioned the allocation of too little taxable profit . . .
“Ireland will probably face censure from European authorities within months in relation to its tax dealings with Apple Inc.,” write Gaspard Sebag and Joe Brennan of Bloomberg Business, quoting unnamed sources. See: Bloomberg Business.
The European Commission, in January 26 announcements, has requested applications from transfer pricing specialists to serve on the EU Joint Transfer Pricing Forum (JTPF). The. . .
The General Court of the European Union on October 7 ruled that a Spanish tax incentive which allows for amortization of goodwill in foreign company share acquisitions is not incompatible with EU state aid rules. As such, the Court annulled 2009 and 20011 European Commission decisions . . .
The European Commission, on July 18, released “Taxation paper No 43: Financial Activities Taxes, Bank Levies and Systemic Risk,” written by Giuseppina Cannas, Jessica Cariboni, Massimo Marchesi, Gaëtan Nicodème, Marco Petracco Giudici, and Stefano Zedda. For the text, see Taxation paper.
The European Commission on October 19 asked the Netherlands to amend the limitation on benefits clause in its tax treaty with . . .
Andorra and the EU on October 4 agreed to automatically exchange information on the financial accounts of each . . .
The European Commission on September 25 launched a public consultation seeking stakeholder input on reform of the EU’s VAT system relating to . . .
An advance pricing agreement (APA) issued to Amazon by the Luxembourg tax authorities setting the price of intra-group royalties seems to be designed to ensure a predictable level of profit to Amazon’s Luxembourg operations rather than to achieve an arm’s length result, and thus appears likely to be state aid, the European Commission . . .
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