The European Commission this week published its final decision on its state aid investigations into transfer pricing rulings granted by Ireland to a U.S. multinational group. Although the decision was announced in August 2016, publication was deferred (as is normal in such proceedings), in order to allow any confidentiality issues to be resolved.
The decision (C(2016) 5605 final) [PDF 1.52 MB} confirms the outcome of the EC’s opening decision of June 2014—that the transfer pricing rulings in question constituted illegal state aid. The state aid—estimated by the EC in its August 2016 announcement at up to €13 billion—must be recovered (with interest) by the Irish authorities from the multinational group. Read TaxNewsFlash-Transfer Pricing
The decision is understood to have been appealed both by the taxpayer and Ireland.
Read a December 2016 report [PDF 81 KB] prepared by KPMG’s EU Tax Centre
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