The longstanding view on application of the arm’s length principle is that it is generally based on a comparison of the conditions in a controlled transaction with the conditions in transactions…
Introduction
It has been a few weeks now since the Commission has made public its decisions in the FIAT and Starbucks cases. I understand that the Commission, the countries involved and the…
In order to close this cycle of dissertations about non-discrimination in International Tax Law, we will finish by talking about the specific case of the Andean Countries.
Decision 578 of the Andean…
The 1999 Simmons & Simmons report on administrative practices is now public, together with the responses by Member States. My suspicion was correct: France had reason to keep the documents a…
According to EU law the prevailing divergences between the national tax systems shall not be corrected by unilateral measures that grant fiscal advantages to firms, which are affected by the…
So what were the other discussions at the UN from 19 to 23 October this year? One of the main topics is the continuing work on a withholding tax on technical services. The reason for developing…
An open door for emerging economies or the beginning of the end in international tax co-ordination
In an article published earlier this year,[1. Teijeiro, Opening the Pandora’s Box in the…
Both Starbucks and Fiat represent, if one listened closely to the live press release broadcast, an first salvo by the EU Commission to establish that it has the authority, under a State Aid premise,…
Today the European Commission released its first set of decisions on corporate tax rulings, which it has investigated for over a year. Starbucks Manufacturing EMEA and Fiat Finance and Trade were the…
It is the annual Session of the UN Committee of Experts on International Cooperation in Tax Matters. This Ad Hoc subsidiary body of the Economic and Social Council of the UN (ECOSOC) is responsible…
