Territoriality and the Tax Treatment of Intra-group Transactions
A special tax rule can constitute the reference or normal system of taxation if it […]
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A Non-Selective Financial Tax with a Narrow Scope
The scope of a tax must be objectively defined in order for those excluded from […]
How to Determine Selectivity
A measure is selective when it excludes undertakings that are equally capable of contributing to […]
Selectivity and Tax Measures
The reference system for determining the selectivity of a tax measure must have its own […]
Compensatory Payments and State Resources
Funds used in compensation mechanisms mandated by the state become state resources Introduction The Court […]
It is Difficult to Challenge a Commission Decision Opening the Formal Investigation Procedure
The assessment of the Commission in an “opening decision” is only provisional. The Commission is […]
Amazon and the Difficulty of Finding a Comparable Tax Payer
To apply the Arm’s Length Principle to transactions between two related companies, the Commission must […]
State Aid Measures May not be Funded through Discriminatory Taxes
A tax that is levied on both imported and domestic products but its revenue finances […]
Turnover Taxes Can Be Progressive without Being Selective
Progressive rates can be part of a reference tax system. The reference tax system is, […]
What is the Value of Informal Commission Communications?
An official’s statement can be imputed to his authority if it can be reasonably assumed […]