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The Brexit vote result will change, if it hadn’t already started to, the way in which the EU will approach the most controversial topics – among which, the highly politicized issue of trans-European taxation, where transfer pricing and profit allocation are the key words. The two parties’ position regards after all, the profit allocation – the winners are those who have claimed that UK is losing rather than winning, from being a part of the EU.

I wrote this article on Friday, 24th of June. Naturally, I was impressed not only by the vote results but also by the picture posted on this very morning on the EU website – the picture’s unintentional irony reminds us that we live in a Union which seems to be stuck in the middle of its very own project, overwhelmed by the real life struggles.

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The whole tax reform under work nowadays in Brussels is centered on the reformulation of the concept of tax advantage on a national level that does not cause damage on a European level.
Which brings us to the intragroup transactions and of their prices - the so-called transfer prices, which the Tax Administration wants at market levels; well, in the new context, it's no longer the field of national tax administration, but of the EU's, plain and clear.

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“SA. 38945” could have been just another case about the tax rulings (issued by Luxembourg or other) found unlawful by European Commission. As it was “SA. 38375” (Luxembourg-Fiat Finance), or “SA. 38944” (Luxembourg-Amazon), or “SA. 44888” (Luxembourg-Engie) or the other “ad hoc state aid (S.A.) cases regarding tax base reduction”. But not this time – ”SA. 38945 is a State Aid granted by Luxembourg to McDonald’s, but do not infringe EU rules”. (the press release, here)

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The EU sinks its tax fangs into America's Apple and demands 13 billion dollars 'owed' to Europe. A harsh warning of intolerance to tax arrangements without Brussels' OK. The US grinds its teeth equally harshly, and brutally displays its own intolerance to anyone who might bite into the taxes 'owed' to Uncle Sam. Their warning - hands off our transfer pricing agreements! Do not undermine the (already frail) progress of the BEPS towards reforming international taxation and increasing its transparency.

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Here is the Transfer Pricing Services' "Response to the Roadmap for more efficient law-making in the field of taxation: identification of areas for a move to qualified majority voting (QMV)", which was sent to Brussels on 21 January 2019.    

Dear Madam / Sir,

Thank you for the opportunity to provide our thoughts on adopting “Qualified Majority Voting for certain tax issues”, which is a subject of historic importance,