The NTA contended that it concluded an APA with SMBV for an arm’s length enterprise remuneration for the worth of SMBV as a espresso bean roasting operation.
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On June 27, 2016 the EU Fee published the long awaited Starbucks State Assist decision ( see here ). The EU Fee’s resolution challenges the outcome of the Advanced Pricing Settlement (APA) between the Netherlands Tax Authority (Tax Authority) and Starbucks Manufacturing BV (SMBV), a completely owned and controlled coffee roasting operation. 14 Overview Of Comparability And Of Profit Strategies: Revision Of Chapters I-III Of The Transfer Pricing Guidelines, OECD, July 22, 2010 at p. 48. 12 State help SA.38374, C (2014) 3626, June 11, 2014 closing – Netherlands Alleged aid to Starbucks, at p. thirteen.
11 OECD Transfer Pricing Pointers for Multinational Enterprises and Tax Administrations 2010, OECD (2010) at para. The NTA contended that it concluded … Read the rest