Sayfa 1934.1.3. Some Observations
It is remarkable that the European Commission tests the at arm’s length principle…
By introducing the ‘Prudent independent market operator test’, the European Commission…
Since also negative royalties were possible, one can doubt whether the agreement…
Consequences of this were that the royalties paid by SMBV to AlkiLP wereconsidered…
For the Dutch tax administration, it was difficult to explain to the European Commission…
Another question is whether the Dutch tax authorities should also have analyzed the…
In fact, the Starbucks case has everything to do with the payment of royalties by…
In this respect, I would like to cite Edward D. Kleinbard: …
‘the Starbucks story demonstrates the fundamental opacity of international tax planning,…
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