Espionage
发表于 2025-3-21 18:51:09
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上腭
发表于 2025-3-21 21:31:01
Reforming the Code of Conduct for Business Taxation in the New Tax Competition Environmentween State aid and the Code and discusses some of the work done under the Code, such as on patent boxes and rulings. The Commission’s conclusion is that the Code needs to be reformed so that it remains effective and addresses public concerns about its lack of transparency.
hereditary
发表于 2025-3-22 02:31:57
The Cat and the Pigeons: Some General Comments on (TP) Tax Rulings and State Aid After the Starbuckslications of the Commission decision on the Belgian excess profits scheme (is smart tax competition State aid? Is not curbing BEPS State aid?), it wonders whether the CCTB may have become politically feasible, and it wonders why the Commission does not seem to investigate tax breaks extended by large member States.
抛弃的货物
发表于 2025-3-22 06:32:07
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SPASM
发表于 2025-3-22 11:52:33
State Aid and Taxation: Selectivity and Comparability Analysisthe ECJ is not applying anymore the principle of rule and exception for its selectivity examination. Instead the selectivity examination as such comprises two parts: It must be examined if a measure is selective and if the selective measure is justified and proportional.
痛得哭了
发表于 2025-3-22 15:00:34
State Aid Benchmarking and Tax Rulings: Can We Keep It Simple?ables as part of a transfer pricing analysis. A flowchart to determine when a ruling may be deemed selective is provided. Then mismatches will be addressed in tax treaty situations, like the (de)recognition of permanent establishments. Lastly, the (ir)relevance of the new EU tax ruling database for state aid investigations will be discussed.
allergen
发表于 2025-3-22 18:07:48
Double Taxation Relief, Transfer Pricing Adjustments and State Aid Law 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.
LIEN
发表于 2025-3-23 00:35:50
Double Taxation Relief, Transfer Pricing Adjustments and State Aid Law: Commentsrough three examples where the application of such measures may lead to double non-taxation. The conclusion is drawn that the complete unilateral application of such measures contradicts their purpose and thus is likely to be disproportionate, which may lead to their qualification as State aid.
CRUE
发表于 2025-3-23 04:51:15
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漂白
发表于 2025-3-23 06:13:56
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