Amount B concerns the contemplated simplified and streamlined transfer pricing rules for determining the remuneration for baseline marketing and distribution activities.
We provide an overview of the latest state of affairs of the new tax qualification policy for (foreign) legal forms that will take effect as of January 1, 2025.
It is intended to prevent investment funds qualifying as non-transparent (independently taxable) for a short period of time when the new rules take effect on January 1, 2025.
On November 7, 2024 the Noord-Nederland District Court rendered judgment in a case Meijburg & Co had initiated concerning the interest on tax due charged on a corporate income tax assessment for t ...
It is noteworthy but unfortunate that the Supreme Court skillfully avoided answering the principal question of whether a split interest in itself constitutes a participation.
In essence, the Court of Justice ruled that the anti-profit shifting provision of Section 10a CITA 1969 is not contrary to the freedom of establishment.
