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A Legal Conundrum: Setting the Limits of the Application of the European State Aid Regime While Respecting the Member States’ Tax

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A Legal Conundrum: Setting the Limits of the Application of the European State Aid Regime While Respecting the Member States’ Tax A Legal Conundrum: Setting the Limits of the Application of the European State Aid Regime while respecting the Member States’ Tax Sovereignty Student: Juliette M. Hipp (ANR 223040) Supervisor: Dr. Carla de Pietro Academic Year 2017-2018 A Legal Conundrum: Setting the limits of the Application of the European State Aid Regime while respecting the Member States’ tax sovereignty Master’s thesis International Business Taxation L.L.M International Business Taxation Law Tilburg School of Law Student: Juliette M. Hipp (ANR 223040) Supervisor: Dr. Carla de Pietro Second Assessor: Prof. Dr. S.A. Stevens TABLE OF CONTENTS PREFACE ............................................................................................................................................................ I ABSTRACT ......................................................................................................................................................... II ABBREVIATION LIST ....................................................................................................................................... III Chapter 1. INTRODUCTION .............................................................................................................................. 1 1.1 Introduction of the topic ............................................................................................................................ 1 1.2 Research question and sub-questions ........................................................................................................ 3 1.3 Motivation of the study.............................................................................................................................. 4 1.4 Methodology .............................................................................................................................................. 5 1.5 Outline of the paper ................................................................................................................................... 5 1.6 Limitations ................................................................................................................................................. 6 Chapter 2. THE NORMATIVE FRAMEWORK OF FISCAL STATE AID .................................................. 7 2.1 Introduction ............................................................................................................................................... 7 2.2 The main functions of State Aid within the internal market...................................................................... 7 2.2.1 The objective of controlling (fiscal) State aid from a competition point of view ............................... 7 2.2.1.1 The EU Competition Policy and the importance of ensuring a ‘fair competition’ .................. 7 2.2.1.2 State Aid control as a key element for market integration .......................................................... 9 2.2.1.3 The economic effects of fiscal state aid ....................................................................................... 9 2.2.2 Fiscal State Aid as a vector of Tax Competition between Member States ....................................... 11 2.2.2.1 The rise of the phenomenon of tax competition within the EU over the past two decades ....... 11 2.2.2.2 The political impact of the tax scandal LuxLeaks ..................................................................... 13 2.3 The concept of tax sovereignty as applied within the European Union .................................................. 14 2.3.1 Defining tax sovereignty .................................................................................................................. 14 2.3.2 The correlation between tax sovereignty and competition distortions ............................................. 16 2.4 The notion of fiscal State aid as defined in the TFEU and interpreted by the European Courts ............. 17 2.4.1. An advantage ................................................................................................................................... 17 2.4.2 Granted through a State .................................................................................................................... 18 2.4.3 Affecting trade and competition between the Member States .......................................................... 19 2.4.4 The tax selectivity ............................................................................................................................. 20 2.4.4.1 The rift between general and selective tax measures ................................................................. 20 2.4.4.2. Test of abstract tax selectivity: three step-test developed through ECJ case law ..................... 21 2.4.4.2.1 First step: Defining the Reference system of taxation ........................................................ 22 2.4.4.2.2 Second step: derogation from the reference system .......................................................... 23 2.4.4.2.3 Third step: justification by the Nature of the System of reference ...................................... 25 2.4.4.3 Opposition between de jure and de facto selectivity ................................................................. 26 2.4.4.4 The restricted approach of the Court of Justice ......................................................................... 28 2.4.4.5 The limits of the selectivity test ................................................................................................. 30 2.5 Conclusion ............................................................................................................................................... 30 Chapter 3. THE ENFORCEMENT FRAMEWORK OF THE LAW GOVERNING FISCAL STATE AID: THE EVOLUTION OF THE COMMISSION’S APPROACH............................................................. 32 3.1 Introduction ............................................................................................................................................. 32 3.2 The growing influence of the Commission on the progressive shaping of the European policy on fiscal State aid ......................................................................................................................................................... 33 3.3 Applying the regime of fiscal state aid to tax rulings .............................................................................. 34 3.3.1 Tax Rulings: A form of Public action and the incentive behind it ................................................... 34 3.3.2 The tax authorities’ margin of discretion potentially leading to a deviation from the reference system ........................................................................................................................................................ 35 3.3.3 The key role of Transfer Pricing and the theory of the Arm’s length principle in the context of fiscal state aid ............................................................................................................................................ 37 3.4 How to establish the presence of a selective advantage: the problematics deriving from the application of the selectivity test to tax rulings ................................................................................................................ 39 3.4.1 The existence of a multitude of transfer pricing methods to allocate profits.................................... 39 3.4.2 The Commission’s broad approach to the application of the selectivity criteria in profit allocation cases ........................................................................................................................................................... 40 3.4.2.1 Apple Case ................................................................................................................................. 41 3.4.2.1.1 Factual and legal background ............................................................................................. 41 3.4.2.1.2 Legal issues ......................................................................................................................... 41 3.4.2.1.3 The Commission’s decision and its supportive arguments ................................................. 42 3.4.2.2 Starbucks Case ........................................................................................................................... 44 3.4.2.2.1 Factual and legal background ............................................................................................. 44 3.4.2.2.2 Tax related question ............................................................................................................ 45 3.4.2.2.3 Commission’s decision and legal analysis ......................................................................... 45 3.4.2.3 Fiat Case .................................................................................................................................... 46 3.4.2.3.1 Factual and legal background ............................................................................................. 46 3.4.2.3.2 Tax related question ............................................................................................................ 47 3.4.2.3.3 Commission’s Decision and its reasoning .......................................................................... 47 3.4.2.4 Amazon Case ............................................................................................................................
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