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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.

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.

Letter sent to Lower House of Parliament summarizing internet consultation and setting out follow-up process to strengthen combating of dividend stripping

July 19, 2022
In practice, large amounts in dividend tax are avoided via various forms of dividend stripping, which the Dutch tax authorities cannot properly combat with the legal instruments currently available to ...

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 ...

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.

Pro Memoria 2022

January 25, 2022
An easy-to-use reference work that will help businesses, institutions and organizations in their accounting practices. The tax rates, premiums and contributions for 2022 have been summarized for your ...

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 ...

European Commission publishes proposal for a directive to tackle the misuse of shell entities

December 28, 2021
On December 22, 2021 the European Commission published a proposal for a directive aimed at preventing the misuse of shell entities and arrangements for tax purposes.

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).

Internet consultation on dividend stripping

December 15, 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 ...

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