Transfer pricing case law in Europe
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2 Transfer pricing case law in Europe
3 The team Frank Schwarte Robert Hartley Roderik Bouwman Legal Business Day Transfer pricing case law in Europe
4 What is transfer pricing? Profit allocation within multinational company Intercompany prices for goods and services Arm's length principle Legal Business Day Transfer pricing case law in Europe
5 What is the problem? Aligning transfer pricing (economics) with tax structuring (law) Double taxation Penalties and interest Legal Business Day Transfer pricing case law in Europe
6 Legal framework OECD Model Tax Convention - article 9 OECD Transfer Pricing Guidelines Updated July 2010 DLA Piper Breakfast seminar September 22 The Netherlands: Article 8b Corporate Income Tax Act Legal Business Day Transfer pricing case law in Europe
7 Royalties to Liechtenstein District Court of Breda March 2010 (09/2639) Facts: Dutch BV engaged in manufacturing and sales of cleaning chemicals Group company in Liechtenstein 'owning' recipes and manufacturing know-how License agreement between BV and Liechtenstein Royalty payments of substantial amounts from BV to Liechtenstein Legal Business Day Transfer pricing case law in Europe
8 Royalties to Liechtenstein Court disallowed royalty deductions: No documentation No substance in Liechtenstein Royalty payments considered non-arm's length and merely a cover for payments to a tax haven Substance! Legal Business Day Transfer pricing case law in Europe
9 Cleaning products - domestic! District Court of Breda 2009 (07/174) Brothers! Mr. X (Netherlands) Mr. Y (Netherlands) 60% 40% 100% A BV (Netherlands) Invoice B BV (Netherlands) Invoice Unrelated supplier Physical delivery of cleaning products Company B had significant tax losses Legal Business Day Transfer pricing case law in Europe
10 Cleaning products Court adjusted profits of A and B Non-arm's length prices Large profits for only buy-sell "CUP" Transaction only aimed at using tax losses in B Transfer pricing in domestic situation Affiliation through family relationship Legal Business Day Transfer pricing case law in Europe
11 Intercompany loans Dutch Supreme Court 2008 (43 849) Before 1995 After 1995 Group of Group of individuals B individuals A Group of individuals A 100% 100% Group C (Multinational) 76% Holding (Netherlands) 24% Loan: EUR 6 million Group C (Multinational) Legal Business Day Transfer pricing case law in Europe
12 Intercompany loans Holding Empty Loan features No agreement No repayment Interest not paid but accrued No collateral Group C Losses from 1996 to 2000 Negative equity No dividend payments since 1995 Legal Business Day Transfer pricing case law in Europe
13 Intercompany loans In 2001 sale of loan of EUR 6 million for EUR 3 million Loss of EUR 3 million, Supreme Court disallowed deduction: Loan completely non-arm's length Only benefit of shareholders was served Questions / open points: Why not just adjust the interest rate? Does this imply reclassification of debt to equity? What about the interest payments? Group of individuals A 76% 100% Holding (Netherlands) 24% Group C (Multinational) Loan: EUR 6 million Legal Business Day Transfer pricing case law in Europe
14 IP sale-and-license-back District Court of Breda 2007 (05/1352) January 1994 July 1994 Holding BV (Netherlands) Holding BV (Netherlands) 100% 100% 100% 100% A BV (Netherlands) Sale of trademark B BV (Netherlands) A BV (Netherlands) License-back of trademark Royalty payments B BV (Dutch Antilles) Legal Business Day Transfer pricing case law in Europe
15 IP sale-and-license-back Facts Sporting shoes Sale and license-back of trademark B BV moves to Dutch Antilles Annual royalties of around EUR 200K Court disallowed royalty deductions: Royalty payments non-arm's length No substance Only tax motives Sale-and-license back was disregarded (!) for tax purposes Legal Business Day Transfer pricing case law in Europe
16 Coca-Cola Spanish Supreme Court 2009 RJ210/1324 The Coca-Cola Company (US) 100% 100% A SL (Spain) B AG (Switzerland) Sale of concentrate No royalty payments to IP-owner (US) Legal Business Day Transfer pricing case law in Europe
17 Coca-Cola Facts Adjustment of price of concentrate by Spanish customs authorities. Custom prices used for transfer pricing purposes Court: Customs and transfer pricing methods have a common goal: to determine the fair market value of the products sold If a tax authority determines the fair market value of a transaction, it should use the same value for other taxes Legal Business Day Transfer pricing case law in Europe
18 DSG (UK) Sales of (i) insurance products and later (ii) service contracts No transactions directly between members of the Dixons group structures Held that provision was made or imposed between the UK stores operator and the group insurer Further, all the bargaining power lay with the UK group All excess profit over and above a normal rate of return on minimum regulatory capital was to be handed back to the UK Legal Business Day Transfer pricing case law in Europe
19 Zimmer (France) ZUK switched from selling in France (via an affiliate) through a buy/sell arrangement to a tax-beneficial commissionaire structure Held - sales contract concluded by a commissionaire does not bind the principal as regards the commissionaire's client Commissionaire therefore cannot be a permanent establishment of the principal But tax authorities can still attack commissionaire structures on TP principles Legal Business Day Transfer pricing case law in Europe
20 SGI (Belgium) Belgian company: granted interest free loan to affiliate in France; and paid director's remuneration to Luxembourg minority shareholder company/ managing director Both transactions challenged by Belgian tax authorities as gratuitous advantages Rules less favourable than would have been if advantages had been granted to Belgian company ECJ upheld Belgian rules Cross-border transfer pricing rules which are more restrictive than domestic equivalents can therefore be justified Legal Business Day Transfer pricing case law in Europe
21 Contact Frank Schwarte E: T: Robert Hartley E: T: +44 (0) Roderik Bouwman E: T: Legal Business Day Transfer pricing case law in Europe
22 De presentatie is beschikbaar op Twitter mee over Legal Business Day: #LBD10 #dlapiper Kantoor DLA Piper Nederland N.V. Amstelveenseweg JJ Amsterdam T F info.nl@dlapiper.com Legal Business Day Transfer pricing case law in Europe
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