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Tim Sarson (KPMG) takes over Chris Morgan’s long-running update on international issues. This month, Tim examines developments on BEPS, state aid and transfer pricing, among others.

 

Dominic Robertson and Isabel Taylor (Slaughter and May) consider the Apple state aid decision and its impact on other businesses.

News report


  • US tech giant Apple was granted illegal state aid by Ireland, the EC ruled on Tuesday, and must now pay up to €13bn (£11bn) in back taxes, plus interest. 
Shiv Mahalingham (Duff & Phelps) identifies key changes to international transfer pricing guidance, regulations and case law that have occurred in the past few months.
 

A non-confidential version of the Commission’s ‘McDonald’s’ decision has been published, reports Pierre-Régis Dukmedjian & Alejandro Dominguez (Simmons & Simmons Luxembourg LLP).

Kelly Stricklin-Coutinho (39 Essex Chambers) reviews a recent European Commission Communication which includes guidance on its application of the notion of state aid to tax.
 
With even more information at the Commission’s disposal from January next year, it seems inevitable that more fiscal state aid investigations are to come. Liesl Fichardt (Clifford Chance) looks at the Commission’s potential future targets.
 
Card image Jonathan Hare, Stephen Morse, Peter Halford

Jonathan Hare, Stephen Morse (PwC) and Peter Halford (PwC Legal) answer the key questions on the European Commission’s investigations into alleged illegal state aid as a way of tacking perceived corporate tax avoidance.

The EU’s ‘overreach’ on state aid has rankled the US tax authority, as Michael Lebovitz (White & Case) reports.

Peter Halford (PwC Legal) considers AG Kokott’s opinion in the ‘Austrian goodwill’ case, including its implications for the Commission’s appeals to the CJEU in the ‘Spanish goodwill’ cases.

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