State Aid

An analysis from a State Aid perspective. This contribution focuses on the profit split methodology in light of current EU Commission’s investigations in the area of tax rulings and transfer pricing…

Much changed in the world of taxation the last couple of years. The OECD started and finished the BEPS (Base Erosion and Profit shifting) project. The objective of BEPS was to develop rules that…

The European Union’s Court of Justice finally rendered its judgement in the famous Banco Santander and Autogrill cases on 21 December 2016. For state aid specialists and tax lawyers this decision was…

To refresh memories, several months ago I posted part 1 of this study on Kluwer's International Tax Blog: Application of TNMM to Starbucks Roasting Operation: Seeking Comparables Through…

An important question in the context of the recovery of fiscal state aid, is how the amount of the tax advantage to be recovered should be calculated. Recently, the Dutch legislator released a draft…

Tax practitioner’s in the northern hemisphere taking their summer holidays may well have included the OECD discussion draft of 5 July 2016 on the attribution of profits to permanent establishments as…

If the UK leaves the EU, this would have immediate consequences for direct taxation.[1] We saw in the first post that the EU fundamental freedoms, EU provisions on State aid and EU directives and…

This month I am going to present the first part (the justification) of a Congressional proposal that I am working upon for an academic article (I will appreciate any feedback).  Thereafter, Haydon…

Harmonisation of the efforts to discourage tax avoidance in the EU Recently, besides the objective of maintaining a balanced allocation1 (a reflection of the principle of territoriality), the…