The ECJ Apple Judgment: A Sour Tarte Tatin

This article comments on the judgment of the ECJ of 10 September 2024 in the so-called Apple case. It analyses how the ECJ approached the Authorised OECD Approach and the arm’s length principle through the lens of the authors, two transfer pricing practitioners. The article also links the Apple case to earlier approaches adopted in judgments rendered in Amazon, Fiat and Engie.