The Commission had announced the opening of a case (11th June), at the same time, another case judged tax regime of Apple in Ireland and Fiat Financial and Trade in Luxembourg. Since those cases, the Commission has opened a fourth enquiry about Amazon in Luxembourg.
Concerning Starbucks, the company which is concerned, is a subsidiary based in the Netherlands (Starbucks Manufacturing BV).
The Commission is asking about the way in which the calculation has been done about “transfer price”, that means the transactions’s prices be done between companies in the same group.
Those prices have the effect to increase or to reduce the income of a company. Multinational companies use it to create fiscal optimization, sharing benefits and costs between subsidiaries located in severals countries, according to the rate of taxation.
According to OCDE, transfers of prices have to be fixed as if different entities were not tied. Throughout forty pages published on Friday, The Commission formulates a lot of doubts about the respect of this measure by Starbucks and the Dutch tax authority.
According to Brussels, it’s an advantage for Starbucks (through this, the American company can reduce the base of calculation concerning the company’s taxes in the Netherlands), compared to other companies.
Last spring the American company had announced, their intention to move their European headquarters (based in Amsterdam) to London, U.K.
In U.K, methods concerning optimization of taxes are stronger than in the Netherlands.
Julien Coussy & Clément Briole, IEJ1B