OECD Transfer Pricing Guidelines According to the EU Commission
In the EU Commission’s view a tax ruling (hereinafter “APA”) confers on the beneficiary a selective advantage under Art. 107(1) of the Treaty on the Functioning of the European Union (hereinafter “TFEU”) insofar as it leads to a lowering of the tax burden by deviating from the tax that the beneficiary would otherwise be obliged…