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Mismatches in non-arm’s length transfer pricing tackled

March 5, 2021
On March 4, 2021 a public internet consultation was launched on a bill to combat mismatches when applying the arm’s length principle. The bill focuses on informal capital arrangements.

New policy statement on VAT fixed establishments

January 14, 2021
The policy statement, among other things, lays down the Dutch viewpoint on the concept of a fixed establishment and the VAT treatment of transactions between a head office and a fixed establishment.

CJEU: no VAT deduction for ‘setting aside’ raised capital after unsuccessful acquisition of a participation

November 16, 2020
If the intended acquisition of a participation cannot be realized, for example due to the corona crisis, we recommend that you examine the VAT implications of this in more detail.

New questions to CJEU: towards a broader concept of fixed establishment for VAT purposes?

October 9, 2020
A Romanian Court recently sought a preliminary ruling from the Court of Justice of the European Union (‘CJEU”) about the concept of fixed establishment for VAT purposes in the Berlin Chemie case (C-33 ...

Impact of transfer pricing adjustments on EU customs valuation

August 27, 2020
Many companies are not aware that retrospective intercompany transfer pricing adjustments could potentially impact the customs valuation of goods imported into the EU. It is therefore imperative that ...

Guidelines on Mandatory Disclosure Rules (DAC6) published

July 1, 2020
During the parliamentary debates on the Dutch implementation of the Mandatory Disclosure Rules (DAC6) it was acknowledged that, in practice, it can be difficult to determine whether or not a certain a ...

Postponement of deadline for notifications under the Mandatory Disclosure Rules (DAC6)

June 29, 2020
Recently, agreement was reached at the EU level on postponing by six months the deadline(s) for notifying reportable cross-border arrangements to the Dutch tax authorities under the Mandatory Disclosu ...

Updated Decree on Mutual Agreement Procedures

June 24, 2020
The Decree provides, from a Dutch perspective, a detailed explanation and interpretation of the implementation of mutual agreement procedures (MAP’s) as regulated in the Tax Dispute Resolution Mechani ...

Transfer pricing in times of crisis: what should you do?

June 18, 2020
On Thursday June 11th, KPMG Meijburg & Cos transfer pricing team organized a webcast to share the first experiences regarding transfer pricing issues in the context of the COVID-19 crisis. We have ...

Transfer Pricing in the Corona Pandemic Disruption Era - an article by our experts

May 20, 2020
The onset of the Covid-19 pandemic has resulted in global business and economic disruptions with a direct impact on the transfer prices of multinational enterprises. Dianne Berry, Marcus Chadderton, a ...

Advocate General at CJEU: VAT deduction limitation for ‘setting aside’ capital raised in expectation of new investment

May 18, 2020
As a result of the corona crisis, setting an investment on hold and holding the capital raised for it may occur more frequently. If the capital is held in expectation of a new investment, we believe i ...

CJEU in Dong Yang case: subsidiary could be a fixed establishment for VAT purposes

May 7, 2020
On May 7, 2020 the Court of Justice of the European Union (‘CJEU’) rendered judgment in the Dong Yang Electronics case (C-547/18). The case concerned whether a subsidiary may, for VAT purposes, consti ...

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