The European Commission has made some surprising decisions in recent years about how tax rulings between multinationals and EU member states constitute state aid. In the second of this two-part series of articles, Carina Lange, senior consultant at CEG Global in the Netherlands, discusses how multinationals can maintain legal certainty and assess the risks associated with tax rulings.
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The court emphasised that TP analysis must adhere to the arm's-length principle, be based on the specific facts of each transaction and comply with domestic regulations, one expert says
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Gilles Roth, speaking at the Luxembourg Transfer Pricing Association’s launch event, also said that his country is ‘carefully considering’ the implementation of amount B
The ruling in January was the first time the court had unanimously upheld a taxpayer's position in a case concerning TP, according to a lawyer who worked on the case