Edited by Christiana HJI Panayi, Werner Haslehner and Edoardo Traversa
Chapter 20: Transfer pricing rules and State aid law
In this chapter, Werner Haslehner addresses the interaction of State aid law with transfer pricing rules. A number of high-profile investigations into transfer pricing arrangements approved by Member States’ authorities, including for companies such as Amazon, Apple and Starbucks, has sparked fierce debate over the existence of an EU principle of ‘arm’s length’ taxation and its possible content. The chapter examines this debate and issues pertaining to the relationship between State aid law and double taxation treaties, justifications on the basis of providing double tax relief or protection from tax avoidance and the scope of administrative discretion that State aid law needs to accord in such a highly technical area of national law as transfer pricing.
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