Territoriality and the Tax Treatment of Intra-group Transactions* A special tax rule can constitute the reference or normal system of taxation if it is “severable” from other tax rules and has its own legal logic. Introduction The application of State aid rules to the tax treatment of transactions between companies that belong to the same multinational group is contentious. During the past three years or so, the Commission won three cases (Fiat [September 2019], Engie [May 2021], UK CFC [June 2022]), but lost four (Starbucks [September 2019], Apple [July 2020], Amazon [May 2021], Gibraltar [April 2022]). The Commission also won two other cases on procedural grounds (Belgium [September 2021], Nike [July 2021]). The Commission’s latest success was on 8 June 2022 in cases T‑363/19 and
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The EU General Court issues a decision on the application of State aid rules to the tax treatment of transactions between companies that belong to the same multinational group (ITV)
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