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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 ...
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Getting tax data right with compliance by design

June 4, 2021
Many tax teams spend the bulk of their time dealing with tax data — finding it, correcting it, reconciling it and formatting it for tax reporting and other compliance needs. But processes like these a ...
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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.
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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.
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Blueprints on Pillar One and Pillar Two: Is your compliance process ready for global digital taxation?

October 26, 2020
Earlier this month we took note of the announcement of the OECD/G20 Inclusive Framework for their Blueprints of Pillar One and Pillar Two as we were curious to see what this would entail.&nb ...
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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 ...
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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 ...
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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 ...
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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 ...
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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 ...
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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 ...
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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 ...
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