Transfer Pricing Times – September 2019

In the “European Court Decisions on Starbucks and Fiat State Aid Cases” article, we discuss recent decisions by the General Court of the European Union on two major State Aid cases dealing with the Luxembourg tax authority's ruling for Fiat Chrysler Finance Europe and the Dutch tax authority's ruling for Starbucks Manufacturing EMEA BV.

In the “OECD Releases MAP Statistics for 2018” article, we review interesting statistics put out by the OECD’s pertaining to Mutual Agreement Procedure (or “MAP”) cases.

In the “Australia Court Rules in Favor of Glencore in Transfer Pricing Case” article, we summarize the Federal Court of Australia’s decision in the case of Glencore Investment Pty Ltd v. the Commissioner of Taxation on September 3, 2019.

In the “Italy: Recent Developments Concerning Patent Box Regime” article, we address changes to patent box framework in Italy that makes it easier for Italian taxpayers to achieve related tax benefits.

Finally, in the “ATO Issues Draft Guidance on the Thin Capitalization Arm’s Length Debt Test” article, we discuss the Australian Taxation Office publishing administrative guidance to taxpayers in applying the arm’s length debt test contained in the thin capitalization rules.

We hope that you will find this and future issues of Duff & Phelps' monthly transfer pricing newsletter informative and reliable.