Brewing Transfer Pricing: Unravelling the Starbucks Case

Abstract

This article analyses the Starbucks case solely from a transfer pricing standpoint, without delving into the merits or discussion on State aid. The analysis is based on the four-step transfer pricing framework: accurate delineation of the transaction, recognition of the transaction, selection of the most appropriate transfer pricing method, and application of the selected method. The article focuses exclusively on the European entities of the Starbucks group that were part of the State aid discussion.