The US Treasury has criticised the European Commission’s (EC) policy of penalising American multinational companies for avoiding tax via state aid deals with individual EU member states.
Many of the conglomerates concerned are companies owned by the US. These include Apple, Starbucks and Amazon – although the partly owned Italian company Fiat is also among them. They are said by the European Commission to have been given preferential ‘advance tax rulings’ from national governments concerning the corporation tax treatment of their monetary arrangements and structures, particularly on transfer pricing.
Where these government tax rulings are over-generous to the company concerned, in order to attract inward investment, the EC views them as illegal state aid, and can demand the company to pay the Commission’s estimate of any unpaid corporation tax respectively.
This week, the US administration published a white paper issued by a US Treasury official who advised the Commission to ‘return to the system of international tax cooperation that has long fostered cross-border investment between the United States and EU Member States’.