Fiat remains "convinced" of the legitimacy of the tax ruling process relating to Fiat Finance and Trade in Luxembourg and believes that "the potential financial impact of the case on the group is not significant". Thus the Lingotto replica replicates theEuropean antitrust, which in recent days accused the auto company that in 2012 it signed an agreement with the Luxembourg tax authorities contrary to EU rules on illegal state aid.
In Piazza Affari, after -3,4% on Monday and -2,55% yesterday, the Fiat share recovered by 1,5% at the opening (to 7,55 euros), posting the best increase in Ftse Mib, which in the same minutes travels in the red by 0,4%.
The group led by Sergio Marchionne says that Fiat Finance "performs treasury and financing activities for the operational activities in Europe. The company has never requested any exemption or tax relief in connection with the ruling, the sole purpose of which is to clarify the transfer pricing rules to be applied in financing activities within the group".
The period under examination is limited to the years 2012 and 2013. The group however specifies that "any potential of the taxable base of Fiat Trade would not be significant compared to the results reported by the group and moreover would lead to opposite changes in other tax jurisdictions, which should be agreed between the Luxembourg tax authorities and the tax authorities of the other European countries affected by the intra-group financing relationships".
Finally, Fiat notes that the tax rate in Luxembourg is similar to that of other European tax systems and that in the period under review the group recorded tax-relevant losses in its European activities: the company "continues to believe that any examination of the matter by the Authorities can only lead to the confirmation of the legitimacy of the tax ruling issued at the time".
