Stephen Daly
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Monthly Archives: October 2019
When is a tax ruling an ‘intervention’ for the purposes of State aid?
For the purposes of Article 107 TFEU, State aid arises where: there has been an intervention by the State or through State resources the intervention gives the recipient an advantage on a selective basis competition has been or may be distorted; … Continue reading
Posted in Tax Law
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The doctrine of legitimate expectations in Aozora – normative underpinnings and the public interest in tax collection
Judgment of the Court of Appeal in the Aozora case ([2019] EWCA Civ 1643) was handed down on 8 October. The Court of Appeal upheld the decision of the High Court and thus dismissed the appeal. In the process however, … Continue reading
Posted in Tax Law
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The General Court’s decisions in Fiat and Starbucks
The General Court has handed down the first judgments in the rulings cases (see here for a note on the Belgian Excess Profits case, which concerns a scheme rather than the application of law). In Fiat, the Court found that … Continue reading
Tax Authority Advice and the Public
There have been many developments in the tax world in the last six months and to that end, the lack of blogging on this site has certainly not been because there is little to discuss. Rather, my efforts have been … Continue reading