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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 ...

New Dutch Transfer Pricing Decree

July 1, 2022
The new Dutch Transfer Pricing Decree was published on July 1, 2022.  The new decree focuses on recent developments that have resulted in changes to the OECD Transfer Pricing Guidelines but also ...

Group company not a fixed establishment for VAT purposes, but CJEU has left the door open

April 11, 2022
The CJEU provided more guidance on the circumstances in which the human and technical resources of an independent legal entity could result in a separate fixed establishment.

Ministry changes stance on severance paid to cross-border workers

February 14, 2022
The Dutch Ministry of Finance has issued new guidance on the allocation of the right to tax severance payments of cross-border workers.

Good Practices Tax Control Framework: next steps

January 13, 2022
In its webinar on January 13, 2022, the Dutch Tax and Customs Administration, in collaboration with the Dutch Association of Tax Advisors, provided further details on the background to the Good Practi ...

Good Practices Tax Risk Management

December 17, 2021
Praktijkvoorbeelden om een globaal beeld te geven van hoe een organisatie kan omgaan met verschillende elementen van het Tax Control Framework (TCF).

Supreme Court renders judgment on the standard practice criterion in the work related costs rules

November 15, 2021
On November 12, 2021 the Supreme Court rendered judgment in the proceedings initiated by KPMG Meijburg & Co concerning whether net share bonuses can qualify as part of the final levy for the purpo ...

Year end 2021 tax accounting considerations

November 12, 2021
As the end of the year is fast approaching, many organizations will soon start preparing their year end financial statements. The announced 2022 Tax Plan may have a significant impact on those financi ...

Budget Day 2021: changes to payroll taxes

September 23, 2021
In our memorandum we address the most significant changes proposed for payroll taxes and social security contributions.

Without own staff, no fixed establishment for VAT purposes in the case of let property

June 22, 2021
On June 3, 2021 the Court of Justice of the European Union (‘CJEU’) rendered judgment in the Titanium Ltd case (case no. C-931/19). The CJEU ruled that a foreign taxable person that does not have its ...

Internet consultation on dividend stripping

June 7, 2021
In practice, substantial (albeit not easily quantifiable) amounts in dividend tax are avoided via various forms of dividend stripping, which the Dutch tax authorities cannot properly combat with the c ...

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.

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