Double Taxation; State Aid; Transfer Pricing; Tax avoidance
Abstract :
[en] This contribution explores the influence of state aid law on tax measures for the provision of relief from double taxation and the consequences of its application to transfer pricing adjustments. In particular, it analyses the compatibility of measures that prevent merely virtual double taxation and transfer pricing adjustments that might result in “white income”. It also reviews the merits of the Commission’s claim that Member States have to apply the arm’s length standard to transfer pricing adjustments as a matter of State aid law.
Disciplines :
Tax law European & international law
Author, co-author :
Haslehner, Werner ; University of Luxembourg > Faculty of Law, Economics and Finance (FDEF) > Law Research Unit
External co-authors :
no
Language :
English
Title :
Double Taxation Relief, Transfer Pricing Adjustments and State Aid Law