The Resource Does the European Union primary law require member states to make corresponding adjustments?

Does the European Union primary law require member states to make corresponding adjustments?

Label
Does the European Union primary law require member states to make corresponding adjustments?
Title
Does the European Union primary law require member states to make corresponding adjustments?
Creator
Subject
Language
eng
Summary
Although for the time being the directive on tax dispute resolution mechanisms in the European Union has been transposed into the national legislation of the majority of Member States and there is an effective solution for transfer pricing disputes, the taxpayers may need a faster solution for double taxation arising from transfer pricing adjustments. As the double tax burden undermines the internal market, this article analyses whether the European Union primary law could provide taxpayers with a solution. The potential requirement to make a corresponding downward adjustment is analysed in the light of freedom of establishment; moreover, considering the Belgium excess profit scheme, it is also examined whether State aid rules might require a corresponding upward adjustment
Citation source
In: EC tax review. - Alphen aan den Rijn. - Vol. 29 (2020), no. 2 ; p. 97-103
http://library.link/vocab/creatorName
Soom, A
Geographic coverage
  • European Union
  • Europe
Language note
English
http://library.link/vocab/subjectName
  • transfer pricing
  • excess profits tax
  • profit shifting
  • double taxation
  • corresponding adjustment
  • dispute resolution
  • fundamental freedoms
  • State aid
Label
Does the European Union primary law require member states to make corresponding adjustments?
Instantiates
Publication
Label
Does the European Union primary law require member states to make corresponding adjustments?
Publication

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