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Export control legislation can apply to physical goods but also to the sale or transfer of intangible assets such as technology and software. Export control regulations may also have an extraterritorial effect; this applies in particular to US export control regulations. Compliance with export control rules therefore has a multi-legal dimension.

Multinational entities with a consolidated turnover exceeding EUR 750 million are obliged to file an annual Country-by-Country (“CbC”) report. They must submit this to the Dutch tax authorities within 12 months of the end of the reporting year. Failure to comply with these Country-by-Country reporting requirements may result in significant administrative penalties.

Disputes with local tax authorities in one or more countries is a normal mode of operation for most multinational enterprises. Often tax disputes do not stand alone because a tax adjustment in one country may have consequences in another country.

Sometimes, multinational enterprises find themselves faced with double taxation. E.g. when the tax authorities of one state impose transfer pricing adjustments for cross-border transactions without corresponding adjustments being made in the other state.