On 16 December 2021, Advocate General Priit Pikamäe delivered an Opinion in Case C-898/19 P, Ireland v Commission and Others, concerning fiscal advantages granted by Luxembourg to a Fiat group subsidiary, which – if followed by the European Court of Justice – could substantially change the European Commission’s approach in assessing Member States’ tax rulings. Background On 3 September 2012, the Luxembourg tax authorities issued a tax ruling whereby they approved the request of an advance transfer pricing agreement submitted by Fiat Chrysler Finance Europe, formerly known as Fiat Finance and Trade Ltd (“FFT”). Following the opening of a formal investigation, on 21 October 2015, the Commission adopted a decision declaring that the tax ruling at issue constituted incompatible State aid. The
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The EU Court of Justice AG Pikamäe delivers an opinion concerning the fiscal advantages granted by Luxembourg to a subsidiary of a major car manufacturing company which could substantially change the Commission’s approach in assessing member states’ tax rulings (Fiat / Ireland)
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