Ireland Archives - Academy of Tax Law

European Commission vs Apple and Ireland (Appeal)

Arms Length Principle, EU, FP News, International, Ireland, Tax Dispute Resolution, TP Case Summaries, Transfer Pricing / Dr Daniel N Erasmus

The CJEU’s judgment of 10 September 2024 overturned the General Court’s previous ruling, confirming that Ireland’s tax rulingsA tax ruling is a formal decision provided by a tax authority, clarifying how specific tax laws and regulations apply to an individual taxpayer or a corporate entity in particular circumstances. Often sought before a significant financial transaction or investment, tax rulings offer legal certainty by outlining the tax implications and obligations in advance. Such rulings are pivotal for multinational... More to Apple Sales International (ASI) and Apple Operations International (AOI) provided an unfair advantage.

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In-depth Analysis of Ireland’s First Transfer Pricing Case

Dispute Resolution, Europe, Ireland, TP Case Summaries, Transfer Pricing / Dr Daniel N Erasmus

Discover the critical insights from Ireland’s first transfer pricingTransfer pricing is a fundamental concept in international taxation that defines the pricing methods and rules applied to transactions between related entities within a multinational enterprise (MNE). In the context of tax regulations, it governs how prices for goods, services, or intangibles (such as intellectual property) are set when these items are exchanged between different branches, subsidiaries, or affiliates of... More case, impacting multinationals and tax authorities worldwide. Learn about the landmark ruling today.

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Apple vs. European Commission

Arms Length Principle, EU, International, International Tax, Ireland, Postgraduate Programmes in International Tax, Postgraduate Programmes in Transfer Pricing, TP Case Summaries, Transfer Pricing / Dr Daniel N Erasmus

This case revolves around the European Commission’s appeal against the General Court’s decision to annul the Commission’s ruling that Ireland granted Apple unlawful state aidState Aid refers to financial assistance provided by public bodies, typically governments, which can selectively benefit certain businesses or industries. This concept is critical in European Union (EU) law, where such support can distort competition and trade within the single market. State Aid, regulated under EU law, aims to ensure fair competition and prevent Member States from favouring local businesses... More through favourable tax rulingsA tax ruling is a formal decision provided by a tax authority, clarifying how specific tax laws and regulations apply to an individual taxpayer or a corporate entity in particular circumstances. Often sought before a significant financial transaction or investment, tax rulings offer legal certainty by outlining the tax implications and obligations in advance. Such rulings are pivotal for multinational... More.

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