European Commission v Ireland and Apple Sales International (C-465/20 P)

Judgment of 10 Sept 2024

law://eu/cjeu/2020/c-465-20/para_306@2026-11-12

306Thus, in so far as the contested tax rulings reduce the annual amount of tax which ASI and AOE are required to pay in Ireland – as compared, in particular, to non-integrated companies whose taxable profit reflects prices determined on the market and negotiated at arm’s length – those tax rulings involve different treatment that can, in essence, be classified as a derogation and as discriminatory (see, to that effect, judgment of 21 December 2016, Commission v World Duty Free Group and Others, C‑20/15 P and C‑21/15 P, EU:C:2016:981, paragraph 54).

European Commission v Ireland and Apple Sales International (C-465/20 P)

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