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Clarification of anti-transfer pricing mismatch rule in the case of capital contributions

January 24, 2023
On January 24, 2023 Deputy Minister of Finance Mr. Van Rij clarified in a policy statement the scope of one of the measures to combat transfer pricing mismatches.

Pillar 2 Developments

December 22, 2022
On December 20, 2022 the OECD released three components of the Pillar 2 Implementation Framework. Our KPMG Pillar 2 specialists have prepared a summary of the content of these documents.

Inflation and its impact on your transfer pricing

December 19, 2022
In many industries, rising prices are leading to reduced margins. How does that impact transfer pricing? This question is especially relevant if your company’s transfer pricing model is based on guara ...

New referral to the CJEU – Net taxation – Taxation of dividend income received by a non-resident insurance company

December 14, 2022
On December 14, 2022 the Court of Appeals in ‘s-Hertogenbosch asked the Court of Justice of the EU (CJEU) for a preliminary ruling in a case dealing with net taxation.

EU reaches agreement on Pillar 2

December 13, 2022
This is a significant development as the EU is considered a first mover. Other countries are now likely to follow.

VAT in the Digital Age proposal issued to modernize the EU VAT system

December 9, 2022
The proposal from the European Commission covers three issues: (1) Digital Reporting Requirements (2) the VAT treatment of the platform economy and (3) changes to e-commerce rules and a ‘single VAT re ...

Court of Justice of the European Union rules that the UBO register must not be publicly accessible

November 23, 2022
The Minister of Finance has asked the Dutch Chamber of Commerce to temporarily stop providing information from the UBO register, effective as of November 22, 2022.

CJEU annuls Commission decision on Luxembourg transfer pricing ruling

November 14, 2022
The decision of the Court of Justice of the European Union brings key clarifications with regard to the choice of a reference system in transfer pricing State aid reviews.

Dutch Supreme Court persists with strict interpretation of actual use for VAT recovery right purposes

November 11, 2022
This case is not only relevant for financial institutions, but also for other taxpayers performing VAT-taxed and VAT-exempt services.

Policy statement on Hybrid Mismatches updated; no longer double taxation in cost-plus situations

November 3, 2022
The spirit and intent of the anti-abuse measures is thus respected.

2022 Decree on Profit Attribution to Permanent Establishments

July 11, 2022
The most important changes are the incorporation of the results of the OECD’s BEPS project and the source exemption that was introduced into the Corporate Income Tax Act 1969 in 2012.

2022 Transfer Pricing Decree

July 5, 2022
The changes to the Decree are mainly a reaction to the changes made to the OECD guidelines in respect of financial transactions, intra-group services and recent OECD publications on the treatment of g ...

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