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

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


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.


Transfer Price Double Taxation Join Case Exemption Method Resident Company 
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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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