Posted in Tax Law

Webinar – EU State Aid – an International Tax Perspective

As already known, Vestager is tackling tax arrangements perceived as an undue State Aid, therefore breaching the TFUE and the original purpose of a proper functioning economy.
But what are potential tax arrangements leading to (unlawful) State Aid

  • Unilateral  advance pricing agreements,
  • Tax ruling including excess profit tax rulings,
  • Audit settlement agreements and
  • other agreements with local tax authorities.

More concretely, the EU commisison can focus on:

  • Transfer pricing (methodology, prefernce for direct TP method, lack ofcomparable benchmarks, lack of documentaiton, appearance of negotiated rulings
  • Profit alocation methods
  • Inconsistent application of national law

Moreover, the slides focus on a US perspective and how such authorities are concerned on these new rulings (retroactivity, based on OECD -therefore not internationally agreed- standards and second-guess local tax authorities).

Finally a list of suggestion on what to do.

Slides here and  introduction+link to recordings, here.

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Junior Legal Counsel with a remarkable lust for legal and business knowledge

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