Ramiro Morales

Introduction On 28 November 2024, the European Commission adopted Decision (EU) 2025/2405, formally closing its long-running State aid investigation into the Luxembourg tax ruling granted to Amazon in 2003. This decision is significant not because it reopens the substantive transfer pricing debate, but because it confirms, following the Court of Justice’s Amazon judgment, that the assessment of State aid must be strictly anchored in the national corporate income tax framework applicable at...

Introduction The Czech Supreme Administrative Court has upheld additional corporate income tax assessments issued to Aufeer Design s.r.o. for the tax years 2015 and 2016. The dispute centred on substantial advertising fees paid to HERA s.r.o. for the placement of Aufeer banners at various events. The tax authorities classified the arrangement as akin to a related-party relationship, concluding that the remuneration for advertising services was excessive and did not reflect market value. Key...

Introduction In May 2025, the European Commission issued the EU Start-up and Scale-up Strategy, a far-reaching framework aimed at making Europe the world’s most competitive jurisdiction for launching and scaling innovative companies. The Strategy highlights that despite Europe’s strong research base, startups continue to face administrative burdens, slow incorporation procedures, and fragmented rules. To address these, the Commission proposes harmonized company-law tools, digital identity...