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Tax Rulings as State Aid — Part 4: Whose Arm's-Length Standard?

22 Pages Posted: 23 Jun 2017 Last revised: 6 Sep 2017

Ruth Mason

University of Virginia School of Law

Date Written: May 15, 2017

Abstract

In this fourth part in a series of reports on state aid, Mason focuses on the element of “advantage” in EU state aid law, and she criticizes the European Commission’s doctrinal approach to identifying advantages for state aid purposes. In particular, this article addresses the divergence between the EC’s and OECD’s conceptions of the arm’s-length principle.

Keywords: State Aid, Tax, Tax Rulings, Transfer Pricing, Apple

JEL Classification: K34

Suggested Citation

Mason, Ruth, Tax Rulings as State Aid — Part 4: Whose Arm's-Length Standard? (May 15, 2017). Tax Notes, Vol. 155, No. 7, May 2017; Virginia Law and Economics Research Paper No. 2017-19. Available at SSRN: https://ssrn.com/abstract=2990603

Ruth Mason (Contact Author)

University of Virginia School of Law ( email )

580 Massie Road
Charlottesville, VA 22903
United States

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