ALERTS: STATE AID - EUROPEAN UNION - IRELAND - TAX RULING - ARM’S LENGTH PRINCIPLE

Arm’s length principle: The Advocate General Pikamäe calls on the Court of Justice of the European Union to set aside the judgment of the General Court of the European Union in so far as it infringed the provisions governing the division of powers between the Union and its Member States (Fiat a.o.)

*This article is an automatic translation of the original article, provided here for your convenience. Read the original article. On 16 December 2021, Advocate General Priit Pikamäe delivered his Opinion in cases C-885/19 (Fiat Chrysler Finance Europe v European Commission) and C-898/19 (Ireland v European Commission)both concerning the advance tax ruling granted by the Luxembourg authorities to Fiat Chrysler Finance Europe (FFT), a company in the Fiat group which provided treasury and financing services to group companies established in Europe, and relating to transfer pricing within that group. It will be recalled that, by judgment of 24 September 2019 delivered in Joined Cases T-755/15 (Luxembourg v European Commission) and T-759/15 (Fiat Chrysler Finance Europe v European

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  • L’actu-concurrence (Paris)

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Alain Ronzano, Arm’s length principle: The Advocate General Pikamäe calls on the Court of Justice of the European Union to set aside the judgment of the General Court of the European Union in so far as it infringed the provisions governing the division of powers between the Union and its Member States (Fiat a.o.), 16 December 2021, Concurrences N° 4-2021, Art. N° 104174, www.concurrences.com

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