How to fight State Aid cases through a full "value chain analysis" - the Starbucks and Apple cases? (2)

How to fight State Aid cases through a full "value chain analysis" - the Starbucks and Apple cases? (2)
How to fight State Aid cases through a full "value chain analysis" - the Starbucks and Apple cases? (2)
October 21st, 2016
In the public version of the “Starbucks decision” of the European Commission, quite often reference is made to the transfer pricing report of Starbucks. Although no public version of this transfer pricing report is made available, it seems reasonable to conclude that the report did not include a proper value chain analysis.

In the public version of the “Starbucks decision” of the European Commission, quite often reference is made to the transfer pricing report of Starbucks. Although no public version of this transfer pricing report is made available, it seems reasonable to conclude that the report did not include a proper value chain analysis. With respect to the Apple decision of the European Commission, it is too early to estimate this and we most likely have to wait several months for a public available version.

Following these two decisions, i.e. the “Starbucks decision” and the public version of the preliminary Apple decision as published in 2014, we estimate that a properly documented value chain analysis could possibly have mitigated the risk of certain granted APA’s being considered as forbidden “State Aid”.

The focus of an in-depth value chain analysis should be identifying the economically significant and value creating functions within a business and their impact on intercompany pricing, and the parties responsible for the relevant functionality.

This webinar is an excellent opportunity for experienced tax professionals in MNEs to be in a better theoretical and practical position to handle and assess a value chain analysis.

Read more   Register

How to fight State Aid cases through a full "value chain analysis" - the Starbucks and Apple cases? (2)
; posted on
October 21st, 2016
In the public version of the “Starbucks decision” of the European Commission, quite often reference is made to the transfer pricing report of Starbucks. Although no public version of this transfer pricing report is made available, it seems reasonable to conclude that the report did not include a proper value chain analysis.
Follow us by Newsletter and Social Media

Our digital platform enhances your tp experience and is ready to let you discover new and related content.
It provides a range of social features:

- Links to Social media (LinkedIn, Twitter, Facebook, YouTube and Xing)
- Sharing our news by monthly Newsletter(s)
- Discuss key issues with our TPA Global team members via blogs and social media

Copyright © 2016
Transfer Pricing Associates BV.
All rights reserved.

Disclaimer | Privacy

H.J.E. Wenckebachweg 210
1096 AS Amsterdam
T: +31 20 462 3530
E: info@tpa-global.com
I: www.tpa-global.com