Fiat Chrysler Finance Europe v. European Commission
Fiat Chrysler Finance Europe v. European Commission
Jurisdiction
European Union, Court of Justice of the European Union (CJEU)
Summary of Facts
The European Commission concluded that Luxembourg provided illegal state aid to Fiat Chrysler Finance Europe by approving an advance transfer pricing arrangement that did not comply with the arm’s length principle.
Key Issues
The case focused on whether the Commission’s interpretation of the arm’s length principle as an autonomous EU law principle was correct.
Decision and Reasoning
The CJEU annulled the Commission’s original judgment, stating that the Commission should rely on the national tax law of the member state when deciding matters involving state aid.
Importance and Implications
This ruling potentially allows member states to develop their own transfer pricing rules, limiting the Commission’s oversight on state aid cases involving transfer pricing.
