Skip to content

State Aid Rules and Tax Rulings


Phedon Nicolaides

This article reviews the use by the Commission of the arm’s length principle to determine whether advance tax rulings constitute state aid. It argues that the benchmark of “market-based outcomes” is not relevant for group companies. It also argues that the derivation of “market-based outcomes” is an inherently subjective and therefore selective process.
Keywords: Advance Tax Rulings; Arm’s Length Principle; Selective Advantage.

Phedon Nicolaides, Professor at University of Maastricht and College of Europe.


Lx-Number Search

(e.g. A | 000123 | 01)

Export Citation