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.
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