On July 6, 2023 a letter was sent to the Lower House of Parliament in which the Deputy Minister of Finance announced that he intends to amend / relax the ruling policy as of the beginning of October 2 ...
Where the ruling practice used to be seen as a fundamental pillar of the Dutch business climate, the Dutch tax authorities now describe preliminary consultation as ‘an important element of its monitor ...
Interest on tax due and late payment interest also often play a role in the adjustment or reassessment of the profit. Sates involved maintain different national rules on interest, which can result in ...
As of 2024, the Pillar 2 rules will become a reality within the EU and other jurisdictions worldwide. Under Pillar 2, the Global Anti-Base Erosion (GloBE) rules ensure that large multinational enterpr ...
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.
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 ...
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.
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.
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 ...
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 ...
