Friday, August 22, 2014
Search
  
Submit your own News for
inclusion in our Site.
Click here...
Breaking News
Sony Offers New Smart Tennis Sensor
Microsoft to Announce Windows 9 on September Event: report
Acer Unveils New Chromebox CXI and Chromebook 11
Fraunhofer To Showcase The Future Of TV at IBC
Intel, Chunghwa Telecom Team up on Internet of Things
Sharp Launches 12-Mpixel CMOS Sensor for 4k Video
LG Delivers New Bluetooth Minibeam Projector, More L Series Smartphones
HP Reports Revenue Gain
Active Discussions
help questions structure DVDR
Made video, won't play back easily
Questions durability monitor LCD
Questions fungus CD/DVD Media, Some expert engineer in optical media can help me?
CD, DVD and Blu-ray burning for Android in development
IBM supercharges Power servers with graphics chips
Werner Vogels: four cloud computing trends for 2014
Video editing software.
 Home > News > General Computing > EU Inve...
Last 7 Days News : SU MO TU WE TH FR SA All News

Wednesday, June 11, 2014
EU Investigates Corporate Taxation Rules of Apple, Starbucks and Fiat Finance


The European Commission has opened three investigations to examine whether decisions by tax authorities in Ireland, The Netherlands and Luxembourg with regard to the corporate income tax to be paid by Apple, Starbucks and Fiat Finance and Trade, respectively, comply with the EU rules on state aid.

The opening of the investigation gives interested third parties, as well as the three countries concerned, an opportunity to submit comments.

The Commission has been investigating under EU state aid rules certain tax practices in several European countries following media reports alleging that some companies have received significant tax reductions by way of "tax rulings" issued by national tax authorities. Tax rulings as such are not problematic: they are comfort letters by tax authorities giving a specific company clarity on how its corporate tax will be calculated or on the use of special tax provisions. However, tax rulings may involve state aid within the meaning of EU rules if they are used to provide selective advantages to a specific company or group of companies.

Tax rulings are used in particular to confirm transfer pricing arrangements. Transfer pricing refers to the prices charged for commercial transactions between various parts of the same group of companies, in particular prices set for goods sold or services provided by one subsidiary of a corporate group to another subsidiary of the same group. Transfer pricing influences the allocation of taxable profit between subsidiaries of a group located in different countries.

If tax authorities, when accepting the calculation of the taxable basis proposed by a company, insist on a remuneration of a subsidiary or a branch on market terms, reflecting normal conditions of competition, this would exclude the presence of state aid. However, if the calculation is not based on remuneration on market terms, it could imply a more favourable treatment of the company compared to the treatment other taxpayers would normally receive under the European tax rules. This may constitute state aid.

The Commission will examine if the three transfer pricing arrangements validated in the following tax rulings involve state aid to the benefit of the beneficiary companies:

- the individual rulings issued by the Irish tax authorities on the calculation of the taxable profit allocated to the Irish branches of Apple Sales International and of Apple Operations Europe;

- the individual ruling issued by the Dutch tax authorities on the calculation of the taxable basis in the Netherlands for manufacturing activities of Starbucks Manufacturing EMEA BV;

- the individual ruling issued by the Luxembourgish tax authorities on the calculation of the taxable basis in Luxembourg for the financing activities of Fiat Finance and Trade.

The Commission has reviewed the calculations used to set the taxable basis in those rulings and has concerns that they could underestimate the taxable profit and thereby grant an advantage to the respective companies by allowing them to pay less tax.

EC said that Luxembourg, contrary to The Netherlands and Ireland, only provided a limited sample of the information requested, which included the ruling for Fiat Finance and Trade, but not the complete information. It has therefore initiated infringement proceedings against Luxembourg by issuing letters of formal notice.

Apple said it has not received any selective tax treatment from the Irish authorities, while the Irish government said it was confident that it has not breached state aid rules will defend its position vigorously.

Apple in the United States entered into deals with the Irish subsidiaries whereby the Irish units received the rights to certain intellectual property that were subsequently licensed to other group companies, helping ensure almost no tax was reported in countries such as Britain or France.




Previous
Next
UMC To Start 14nm Trial Production Next Year        All News        Toshiba STT-MRAM Memory Reduces Power Consumption Of Processors
UMC To Start 14nm Trial Production Next Year     General Computing News      Synaptics to Buy Renesas SP Drivers For $475 million

Get RSS feed Easy Print E-Mail this Message

Related News
Apple In Talks With Health Providers For Healthkit
Apple, Samsung Agree to End Patent Suits
Next Apple TV Release Delayed
Apple May lay Off People at Beats: report
Samsung And Apple See Their Smartphone Market Shares Plunging
Apple's MacBook Pros Now Come With Faster processors And More Memory
Apple-Beats Deal Cleared By Europe
Swatch Denies Working with Apple on iWatch
Apple OS X Yosemite Bets Coming on Thursday
Apple Says There Are No Backdoors In iOS
Apple's Revenue Boosted By China Growth
Apple Granted Patent for Smartwatch

Most Popular News
 
Home | News | All News | Reviews | Articles | Guides | Download | Expert Area | Forum | Site Info
Site best viewed at 1024x768+ - CDRINFO.COM 1998-2014 - All rights reserved -
Privacy policy - Contact Us .