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Double Taxation Relief, Transfer Pricing Adjustments and State Aid Law: Comments

  • Rita SzudoczkyEmail author
Chapter
  • 864 Downloads
Part of the MPI Studies in Tax Law and Public Finance book series (MPISTUD, volume 6)

Abstract

This contribution examines whether double taxation relief measures and downward transfer pricing adjustments which are granted irrespective of whether or not the income for which such relief is granted has been taxed in another State can constitute State aid under EU law. The question is analysed through three examples where the application of such measures may lead to double non-taxation. The conclusion is drawn that the complete unilateral application of such measures contradicts their purpose and thus is likely to be disproportionate, which may lead to their qualification as State aid.

Keywords

Transfer Price Double Taxation Join Case Exemption Method Resident Company 
These keywords were added by machine and not by the authors. This process is experimental and the keywords may be updated as the learning algorithm improves.

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Copyright information

© Springer-Verlag Berlin Heidelberg 2016

Authors and Affiliations

  1. 1.Vienna University of Economics and BusinessViennaAustria

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