Noteworthy is that the Lower House also agreed to change the MLI position of the Netherlands with respect to preventing the artificial avoidance of permanent establishment status.…

The emergency repair measures mean that for a number of legal provisions the approach to be taken is as if a fiscal unity for corporate income tax purposes does not exist.…

On January 24, 2019, the Court of Justice of the European Union rendered its judgment in the Morgan Stanley & Co International plc case (case no. C-165/17).…

The case concerned insurance policies for M&A transactions and the CJEU judgment provides a welcome clarification.…

Assuming the media is right and the deal between UK and EU will not be accepted by the House of Commons. What does this mean for trade between UK and EU? For sure another period of…

It is a very broadly worded bill and will potentially affect many foundations and associations.…

This Directive provides for the mandatory automatic exchange of information on reportable cross-border arrangements.…

In its judgment, the Supreme Court provided detailed guidelines on how to decide whether the costs incurred relate to the acquisition or disposal of participations.…

On November 8, 2018, the groundbreaking judgment that the Court of Appeal in Amsterdam had rendered on the VAT exemption for the management of special investment funds (SIFs), was…

On December 4, 2018, the Economic and Financial Affairs Council of the EU (ECOFIN) held an exchange of views on the digital services tax, but failed to reach an agreement on a compromise…

The proposed measures cover the elements transparency, process and content in the context of the issuing of all rulings with an international character.…

We have summarized the adopted amendments and the most important adopted motions.…

The emergency repair measures mean that for a number of legal provisions the approach to be taken is as if a fiscal unity for corporate income tax purposes does not exist.…

On October 29, 2018, the government launched an internet consultation to give interested parties the opportunity to respond to the draft bill to implement ATAD2 to tackle hybrid mismatches.…

Meijburg & Co has prepared an overview of the CbCR notification requirements for all countries that implemented final CbCR legislation as of 2016, 2017 and 2018.…

On October 26, 2018, the Memoranda of Amendment resulting from the government’s reconsideration of the business climate package were also published.…

On October 18, 2018, the Court of Justice of the European Union delivered its judgment in the Volkswagen Financial Services (UK) Limited case (C-153/17).…

On October 19, 2018, the Supreme Court rendered its final judgment in two important corporate income tax cases, in which it had previously requested a preliminary ruling from the Court of…

In a letter dated October 15, 2018, the Deputy Minister of Finance announced that the government has decided to leave the dividend tax as is, and to improve the business climate through…

On October 3, 2018, the Opinion issued by the Advocate General to the Court of Justice of the European Union in the Morgan Stanley & Co International plc case (case no. C-165/17) was…

Welcome back! The summer holiday season has come to an end. We hope you had a wonderful summer and are ready to get back into the swing of things. In this Budget Day 2018 Special we have…

Interested parties are given the opportunity to raise issues that are important to them relating to Dutch tax treaty policy and the designation of low-taxed states.…

The main features of the 2019 Tax Plan are addressed in our memorandum.…

Every month we publish an e-newsletter which gives you an overview of international tax developments being reported globally by KPMG member firms in the American, Africa, Europe, ASPAC and…

The discussion draft identifies the areas of disagreement between countries and solicits stakeholder input on these topics.…

Every month we publish an e-newsletter which gives you an overview of international tax developments being reported globally by KPMG member firms in the American, Africa, Europe, ASPAC and…

On June 20, 2018, the European Commission announced its final decision on the state aid investigations into tax rulings granted by the Luxembourg tax authorities to GDF Suez (Engie).…

Requests for certainty have to be submitted from now on to the local tax inspector, who will monitor whether the request is for a standard transaction or whether there are indeed uncertain…

The measures in the bill mean that some Sections of the Corporate Income Tax Act and the Dividend Withholding Tax Act will have to be applied as if there is no fiscal unity.…

This issue of our FS Tax Newsletter contains event summaries of two of our recent seminars, as well as recent developments within the Financial Services sector, such as the mutual agreement…

As a result of the broad definition of an intermediary, DAC6 does not solely target tax advisors but also many other service providers in the legal, financial and consultancy branches.…

Every month we publish an e-newsletter which gives you an overview of international tax developments being reported globally by KPMG member firms in the American, Africa, Europe, ASPAC and…

The announced measures will drastically change the Corporate Income Tax Act in the coming years.…

This decree particularly concentrates on aspects where the 2017 OECD Transfer Pricing Guidelines leave scope for domestic interpretation.…

The AG at the CJEU concluded that a hire purchase transaction is a single supply of a service or a good and the whole supply should be treated as taxable.…

Every month we publish an e-newsletter which gives you an overview of international tax developments being reported globally by KPMG member firms in the American, Africa, Europe, ASPAC and…

The case concerns insurance policies for M&A transactions and could affect many types of cross-border insurance policies.…

This issue of our FS Tax Newsletter contains recent developments within the Financial Services sector, such as the Opinion of the Advocate General in the DPAS Limited case…

Every month we publish an e-newsletter which gives you an overview of international tax developments being reported globally by KPMG member firms in the American, Africa, Europe, ASPAC and…

If the CJEU follows the AG’s Opinion, then the consequences for the Dutch practice would appear to be that there would be an even more limited scope of the VAT exemption for payments.…

The package includes both interim measures, in the form of a 3% Digital Services Tax on revenues, and a long-term solution, introducing the concept of a digital permanent establishment.…

Our two-pager gives you an overview of the key BEPS Actions the MLI focusses on implementing, how it will work, who it will affect and what the next steps should be.…

This is the latest in a series of EU initiatives in the field of the automatic exchange of information in tax matters.…

One letter contained his Tax Policy agenda, while the other elaborated on the first priority of this agenda: combating tax avoidance and tax evasion.…

The Deputy Minister of Finance aims to present the bill containing the emergency remedial measures that had already been announced to the Lower House in the second quarter of 2018.…

The first 2018 issue of our FS Tax Newsletter contains a regular update of recent developments within the Financial Services sector.…

Every month we publish an e-newsletter which gives you an overview of international tax developments being reported globally by KPMG member firms in the American, Africa, Europe, ASPAC and…

Every month we publish an e-newsletter which gives you an overview of international tax developments being reported globally by KPMG member firms in the American, Africa, Europe, ASPAC and…

The Commission will adopt a final decision at the end of the formal investigation.…

This is in spite of non-discrimination provisions in most tax treaties concluded by the Netherlands that prohibit the higher taxation of companies if the shareholder is not established in…

This issue of our newsletter contains our regular update of recent developments within the Financial Services sector. This month we have included an update on the coalition plans to abolish…

Seventeen countries have been placed on a blacklist, 47 committed countries on a grey list and 8 ‘hurricane countries’ (i.e. countries recently affected by tropical storms) have been…

Every month we publish an e-newsletter which gives you an overview of international tax developments being reported globally by KPMG member firms in the American, Africa, Europe, ASPAC and…

We previously informed you about the bill on the ‘Withholding obligation for holding cooperatives and expansion of the withholding exemption Act’. We also informed you about the…

Although the CJEU and the Supreme Court still have to render their final judgments on these cases, the Cabinet has already announced emergency remedial measures.…

A monthly overview of international tax developments being reported globally.…

The tax measures the new Cabinet intends to introduce include reducing the corporate income tax rates, partially abolishing dividend withholding tax, a two bracket regime in Box 1, an…

On October 10, 2017 it was announced that the four parties negotiating the coalition agreement for the new Cabinet intend to abolish Dutch dividend withholding tax, except for in abuse…

This newsletter contains an update with respect to the Funds for Mutual Accounts and the UK Criminal Finances Act. This newsletter also includes a summary of the CJEU court ruling about the…

On October 4, 2017, the European Commission announced its final decision on its state aid investigations into transfer pricing rulings granted by Luxembourg to the Amazon group.…

The CJEU’s ruling that the VAT exemption for cost-sharing groups does not apply to the financial and insurance sector is very important.…

Following the informal meeting of the Economic and Financial Affairs Council (Ecofin) of the European Union held in Tallinn on September 15 and 16, 2017, the European Commission published…

The main features of the 2018 Tax Plan are addressed in our memorandum.…

The proposals are expected to have a significant impact on the use of cooperatives in international structures.…

A monthly overview of international tax developments being reported globally.…

With a negative interest rate, roles are reversed and debtors receive an interest payment from creditors.…

Sector-specific solutions. Comprehensive approach with global focus. Leading technologies. The professionals from the Meijburg Corporate Clients Team focus on advising listed companies…

Every month we publish an e-newsletter which gives you an overview of international tax developments being reported globally by KPMG member firms in the American, Africa, Europe, ASPAC and…

A new edition of 612 pages of the OECD Transfer Pricing Guidelines was published on July 10, 2017.…

Every month we publish an e-newsletter which gives you an overview of international tax developments being reported globally by KPMG member firms in the American, Africa, Europe, ASPAC and…

On July 10, 2017 the Deputy Minister of Finance, Mr. Eric Wiebes, published a document for internet consultation aimed at the introduction or amendment of a number of anti-tax avoidance…

Further to the approval by the European Code of Conduct Group, the OECD has now also concluded that the Dutch Innovation Box does not produce any harmful tax competition.…

The approval relates to the version of the Innovation Box that (for the most part) was introduced as of January 1, 2017, which was included in the 2017 Tax Plan.…

The proposal goes beyond the recommendations of BEPS Action 12 and proposes a wide ranging exchange of information.…

The Multilateral Convention (“Multilateral Instrument” or “MLI”) is in accordance with Dutch policy to combat BEPS on a multilateral basis and the Netherlands has taken a pro-active…

Every month we publish an e-newsletter which gives you an overview of international tax developments being reported globally by KPMG member firms in the American, Africa, Europe, ASPAC and…

Dear FS professional, This newsletter contains information about an important insight from the Dutch Supreme Court on interest deduction, three VAT-related topics and the new insurance…

The administrative burden will increase because investments have to be followed for longer.…

The introduction of a dividend withholding tax obligation for holding cooperatives represents a significant tightening of the current rules.…

Every month we publish an e-newsletter which gives you an overview of international tax developments being reported globally by KPMG member firms in the American, Africa, Europe, ASPAC…

The CJEU ruled that the VAT exemption for cost-sharing groups does apply if the members of a cost-sharing group also perform services subject to VAT, provided the services of the…

On April 26, 2017, US Treasury Secretary Mnuchin and US National Economic Council Director Cohn announced the “core principles” of President Trump’s plan for US tax reform.…

On April 18, 2017 the Lower House adopted the bill on additional rules for the exchange of Country-by-Country reports. In addition to this, on April 6, 2017 the OECD published additional…

Every month we publish an e-newsletter which gives you an overview of international tax developments being reported globally by KPMG member firms in the American, Africa, Europe, ASPAC and…

Contrary to other recent Opinions, the AG considered that the VAT exemption for cost-sharing groups does apply to the financial and insurance markets.…

Dear FS professional, In the FS Tax Newsletter, we provide you with an update on developments in the Financial Services sector. In this edition you will find, among others, a summary of…

Every month we publish an e-newsletter which gives you an overview of international tax developments being reported globally by KPMG member firms in the American, Africa, Europe, ASPAC and…

We welcome the fact that the Supreme Court has decided to request a preliminary ruling.…

The AG concluded that the VAT exemption for cost-sharing groups cannot be applied in the financial and insurance markets and neither in cross border situations.…

On February 21, 2017 the EU Member States reached agreement on a Directive that will amend the Anti-Tax Avoidance Directive (Council Directive (EU) 2016/1164 of July 12, 2016, ’ATAD 1’).…

On February 14, 2017 the new Dutch decree on insurance premium tax was published. This replaces the Dutch decree of February 21, 2014 and contains several changes.…

Transformation of ComplianceRevisiting the model for global tax and statutory compliance. KPMG’s Global Compliance Management Services (GCMS) practice has a world-wide network of…

Every month we publish an e-newsletter which gives you an overview of international tax developments being reported globally by KPMG member firms in the American, Africa, Europe, ASPAC and…

Dear FS professional,  We hope that the New Year got off to a good start for everyone. In the FS field, right at the end of last year, the Supreme Court ruled that pension funds with…

The bill makes it possible to automatically exchange the Country-by-Country report submitted by a Dutch-resident Reporting Entity to the Dutch tax authorities, with the competent tax…

The Court concluded that the disadvantageous difference in tax treatment infringes the EU principle of freedom of establishment.…

The Supreme Court has ruled that pension funds with a defined benefit (DB) plan, as in the case in question, cannot be regarded as a special investment fund within the meaning of the…

Americas Europe & Africa Asia Pacific & MENASA …

According to the compromise text issued on December 2, 2016, the proposed amendments (that would take the form of a directive (‘ATAD 2’) to amend ATAD 1) would have extended the scope…

This bill means that the extension of the fiscal unity regime will now also be formally incorporated into law, after it had already been laid down in supplementary policy statements as a…

The Supreme Court ruled that the VAT exemption can only apply if (the manager of) an investment institution was actually granted a license as referred to in the (then applicable) Investment…

Dear FS professional, This issue of our newsletter contains our regular update of recent developments within the Financial Services sector. This month we have included an update on the…

More than 100 jurisdictions have concluded negotiations on a Multilateral Convention (or ‘multilateral instrument’) that is intended to implement certain tax treaty related aspects of…

On November 21, 2016 the Dutch Deputy Minister of Finance issued a policy statement granting Dutch subsidiaries of multinational enterprises (MNEs) which are subject to Country-by-Country…

Every month we publish an e-newsletter which gives you an overview of international tax developments being reported globally by KPMG member firms in the American, Africa, Europe, ASPAC and…

On October 25, 2016 the European Commission published legislative proposals to relaunch its Common Consolidated Corporate Tax Base initiative, as well as new measures to combat hybrid…

Every month we publish an e-newsletter which gives you an overview of international tax developments being reported globally by KPMG member firms in the American, Africa, Europe, ASPAC and…

In the FS Tax Newsletter, we provide you with an update on developments in the Financial Services sector. In this edition we have summarized among others two new agreements between the…

Every month we publish an e-newsletter which gives you an overview of international tax developments being reported globally by KPMG member firms in the American, Africa, Europe, ASPAC and…

Every month we publish an e-newsletter which gives you an overview of international tax developments being reported globally by KPMG member firms in the American, Africa, Europe, ASPAC and…

The main features of the 2017 Tax Plan are addressed in our memorandum.…

On September 19, 2016 the EU Commission announced that it was opening an in-depth investigation into tax rulings granted by Luxembourg to GDF Suez.…

Depending upon the supervision to which (the managers of ) these funds may be subject, the VAT exemption for the management of these funds may be canceled.…

The state aid has now been determined to be incompatible with the internal market, and must be recovered (with interest) by the Irish authorities from the Apple group.…

The e-newsletter is designed to be a one-stop shop for important news. The June 2016 edition is out.…

Dutch Lower Court refers preliminary questions to Dutch Supreme Court regarding dividend withholding tax reclaim of foreign investment fund and asks it to reconsider its negative decision…

The Advocate General however concluded that further examination of the facts must show whether and, if so, which VAT-taxable service is provided in exchange for the recharged costs.…

One case concerned the limitation on the deduction of interest (profit shifting, Section 10a Corporate Income Tax Act 1969), while the other concerned foreign exchange losses on EU…

Every month we publish an e-newsletter which gives you an overview of international tax developments being reported globally by KPMG member firms in the American, Africa, Europe, ASPAC and…

The Court concluded that the freedom of capital does not preclude a Member State from treating dividends received from another Member State less favorably than those received from a third…

We give an overview of the tax consequences and shortly address the impact for the Netherlands as regards direct taxes.…

The directive is intended to provide a minimum level of protection for the internal market and strengthen the average level of protection against aggressive tax planning.…

Every month we publish an e-newsletter which gives you an overview of international tax developments being reported globally by KPMG member firms in the American, Africa, Europe, ASPAC and…

The key question posed to the CJEU is whether the services performed by Bookit and NEC qualify as “transactions concerning payments and transfers”, which are VAT-exempt.…

The matter has been postponed until the next ECOFIN meeting.…

The proposed changes follow the recommendations made in the final BEPS 5 report issued by the OECD and recent evaluations on the working of the Dutch innovation box.…

The 68 page communication is intended to provide clarification on the key concepts relating to the notion of State aid as referred to in Article 107(1) TFEU and is available in full in the…

The AG concluded that there is no infringement of EU law even though similar interest which was not deductible under Danish domestic thin capitalization rules would have been exempted. …

Court of Appeals allows fiscal unity between Dutch sister companies even if the parent company is established in a country outside the European Union.…

By policy statement dated April 25, 2016, the Deputy Minister of Finance followed-up on the final judgment of the Dutch Supreme Court in the Miljoen, X and Société Générale cases.…

With the exception of some changes, the final proposal does not deviate significantly from the circulated draft.…

Meijburg & Co has an EU Tax Law app that contains all the rulings (including opinions) from the Court of Justice of the EU for Direct Tax, VAT and Social Security Tax, pending cases,…

The proposal would require multinational groups with a total consolidated revenue of EUR 750 million to report either if they are EU parented or otherwise have EU subsidiaries or branches.…

The Supreme Court has ruled that a VAT taxable business can deduct the VAT charged on the costs incurred for the management and the business activities of its own company pension fund.…

Every month we publish an e-newsletter which gives you an overview of international tax developments being reported globally by KPMG member firms in the American, Africa, Europe, ASPAC…

This is a first step towards the formal adoption of the European Commission’s proposal.…

The Supreme Court ruling is favorable for foreign individuals with shares in Dutch companies.…

Every month we publish an e-newsletter which gives you an overview of international tax developments being reported globally by KPMG member firms in the American, Africa, Europe, ASPAC and…

Every month we publish an e-newsletter which gives you an overview of international tax developments being reported globally by KPMG member firms in the American, Africa, Europe, ASPAC and…

The new package not only aims at implementing, in a coordinated manner, the OECD standards at the EU level, but goes beyond these recommendations.…

These are exciting times for Section 13l Corporate Income Tax Act 1969, the relatively new (three years old) provision in the corporate income tax that restricts the excessive deduction of…

The European Commission has concluded that selective tax advantages granted by Belgium under its excess profit tax scheme constitute state aid, incompatible with the internal market…

The rules governing transfer pricing documentation including Country-by-Country Reporting, Master File and Local File are effective as of January 1, 2016.…

Every month we publish an e-newsletter which gives you an overview of international tax developments being reported globally by KPMG member firms in the American, Africa, Europe, ASPAC and…

The amendments will, at the earliest, be included in the 2017 Tax Plan, which will be presented on Budget Day 2016.…

On December 9, 2015, the Court of Justice of the European Union (“CJEU”) ruled in the Dutch Fiscale Eenheid X case (C-595/13) that the VAT exemption for the management of special…

Estonia has indicated that it no longer supports the proposal.…

Dear FS professional, In the final FS Tax Newsletter for 2015 we would like to update you on recent developments within the Financial Services sector. We would also like to inform you…

The CRS, developed by the OECD and largely based on FATCA, is a standard that governs the exchange of financial account information and will be implemented by the ‘CRS states’.…

On 27 November 2015 the Netherlands announced it will appeal against the EU Commission’s decision in the State Aid case.…

According to a recent judgment rendered by the Amsterdam Court of Appeals (case no. 15/00074), the provision of market data against consideration and the supply of technical services should…

It concerns advanced tax rulings (ATRs) that, as a result of expected adoption of the Parent-Subsidiary Amendment (Implementation) Act 2015 by the Lower House, would lose their validity.…

Every month we publish an e-newsletter which gives you an overview of international tax developments being reported globally by KPMG member firms in the American, Africa, Europe, ASPAC and…

As expected, the tax treaty with Germany has been ratified, which means that it will apply as of January 1, 2016.…

These decisions confirm the Commission’s preliminary view that the transfer pricing rulings granted by the Netherlands and Luxembourg to companies in two multinational groups involved…

On July 27, 2015 the Court of Appeals Arnhem-Leeuwarden (the “Court”) rendered judgment on the deduction of VAT charged on costs that a company pension fund recharged to the…

With this amendment, the EU is broadly in line with the final BEPS Action Plan, and particularly Action 5, which was published on October 5, 2015.…

Dear FS professional, Every other month you receive an update from us on developments in the Financial Services sector. In this edition of the FS Tax Newsletter we have summarized the…

The release of the final recommendations does not mean that the book on BEPS can now be closed.…

Every month we publish an e-newsletter which gives you an overview of international tax developments being reported globally by KPMG member firms in the American, Africa, Europe, ASPAC and…

On September 10, 2015 the Lower House approved the new bilateral rules for the avoidance of double taxation between the Netherlands – including its Caribbean territories (i.e. Bonaire,…

The proposed CbC Reporting and documentation requirements constitute a ground breaking change from the current Dutch documentation requirements.…

The decision offers possibilities for claiming, in cross-border situations, certain benefits available under the Dutch fiscal unity regime in domestic situations.…

Source: NTFR Artikelen 2015/6Author: Bauco Suvaal In an article that the author wrote in 2011, he, along with others, expressed the hope that the updating of the Decree, dated May 6, 2008,…

Dear FS professional,  While some of you are (hopefully) able to enjoy some time off, we would like to provide you with some food for thought on the developments that have taken place…

Every month we publish an e-newsletter which gives you an overview of international tax developments being reported globally by KPMG member firms in the American, Africa, Europe, ASPAC and…

In this case, the CJEU broadly interprets the VAT exemption for insurance.…

The Dutch Supreme Court did not rule in favor of the Luxembourg investment fund and denied the request for a refund of the Dutch dividend withholding tax.…

This document provides for a summary and the status of the OECD Action Plan on Base Erosion and Profit Shifting (“BEPS”), as per June 2015. We will first summarize the recent…

The AG concluded that withholding tax imposed on a non-resident may not exceed the individual income tax burden of a resident taxpayer.…

As foreseen, this includes a proposal to re-launch the Common Consolidated Corporate Tax Base (CCCTB).…

Every month we publish an e-newsletter which gives you an overview of international tax developments being reported globally by KPMG member firms in the American, Africa, Europe and ASPAC…

The decision was primarily based on the fact that a similar loss could arise on shares in a domestic company and this would also be non-deductible.…

The CbC implementation package can assist jurisdictions with the effective local implementation of CbC Reporting and consists of model legislation and three model Competent Authority…

The decision to open a formal state aid procedure is another indication that the Commission is continuing to challenge the transfer pricing tax practices of the EU Member States.…

The discussion draft explains the difficulties faced by tax authorities in verifying the arm’s length basis on which pricing is determined by taxpayers for transactions involving a…

Dear FS professional,  Before the holiday season begins, we would like to update you on the hot topics in the FS sector. This newsletter provides updates on three VAT-related topics:…

Advocate General Kokott advises the CJEU to qualify a real estate investment fund as a ‘special investment fund’, as long as this fund is under special regulatory supervision.…

The revised discussion draft deals with issues relating to the Limitation on Benefits provision, the Principal Purpose Test and several other issues.…

With the approval by the Upper House of the Dutch Parliament on May 19, 2015, the ratification process of the new tax treaty between the Netherlands and Germany has now virtually been…

Every month we publish an e-newsletter which gives you an overview of international tax developments being reported globally by KPMG member firms in the American, Africa, Europe and ASPAC…

Commodity trading companies today operate in a highly competitive and dynamic environment where change is one of the few constant factors. Complexity of doing business is being increased by…

On 29 April 2015 the OECD published a public Discussion Draft on possible revisions to chapter VIII of the OECD Transfer Pricing Guidelines on cost contribution arrangements (CCA’s).…

Every month we publish an e-newsletter which gives you an overview of international tax developments being reported globally by KPMG member firms in the American, Africa, Europe and ASPAC…

On April 3, 2015, the OECD released a discussion draft which deals with BEPS Action 3: strengthening CFC rules.…

Dear FS professional, In this spring edition of our FS Tax Newsletter you will find an update of several VAT related court cases, such as the hearing on the VAT group X case…

The proposals are part of a package of measures to combat tax avoidance and harmful tax competition.…

Every month we publish an e-newsletter which gives you an overview of international tax developments being reported globally by KPMG member firms in the American, Africa, Europe and ASPAC…

The Advocate General at the Supreme Court, Ms. M.E. van Hilten, recently issued her Opinion in the PPG Holding BV (“PPG”) case in which she concluded that PPG could deduct the VAT on…

Clients who receive a hard copy assessment (or have recently received one) and do not receive (or have not received) notification from us about this although they normally do so, are…

According to the Ministry of Finance, the Skandia judgment does not apply in the Netherlands.…

Every month we publish an e-newsletter which gives you an overview of international tax developments being reported globally by KPMG member firms in the American, Africa, Europe and ASPAC…

The case is important for the scope of the insurance exemption for VAT purposes.…

The Supreme Court ruled that the 8.3% dividend withholding tax pursuant to the Tax Regulations for the Kingdom of the Netherlands (Belastingregeling voor het Koninkrijk, “BRK”) is not…

Dear FS professional,  The year 2015 started with many developments which (may) affect the financial services industry. This edition of the FS Tax Newsletter therefore provides an…

On February 3, 2015, the Court of Justice of the EU rejected the Commission’s complaints against the United Kingdom regarding the compatibility of the UK’s cross-border group relief…

Lower courts have recently ruled in favor of the Dutch Tax Authorities in combating captives. As a result of this, we have noticed that, in its audits, the Dutch Tax Authorities is…

Ministers of 10 EU Member States issued a joint statement to give a fresh impetus to a financial transaction tax (FTT).…

The Dutch Tax Authorities have recently been pro-actively approaching holding and financing companies to question their entitlement to deduct VAT.…

Every month we publish an e-newsletter which gives you an overview of international tax developments being reported globally by KPMG member firms in the American, Africa, Europe and ASPAC…

The decision sets out the factual and legal basis for the Commission’s preliminary view that one of these rulings constitutes state aid.…

This policy statement follows three judgments by the Court of Appeals Amsterdam on December 11, 2014 which concluded that Dutch legislation on the fiscal unity for corporate income tax…

On December 18, 2014, the OECD released a discussion draft which deals with BEPS Action 4: interest deductions and other financial payments.…

The announcement follows recent decisions by the European Commission to initiate formal state aid proceedings against Ireland, Luxembourg and the Netherlands with regard to tax rulings…

On December 17, 2014 the Deputy Minister of Finance announced that the three judgments would not be appealed before the Supreme Court.…

The Dutch Ministry of Finance recently announced that the new regulation for the avoidance of double taxation between the Netherlands and Curaçao is expected to take effect as of January…

More is now known about what was discussed by the ECOFIN on December 9, 2014 about the future of the European patent box regimes.…

On December 11, 2014 the Court of Appeals Amsterdam ruled in three cases that Dutch legislation on the fiscal unity for corporate income tax purposes is contrary to the European freedom of…

On December 9, 2014 the EU Council of Economics and Finance Ministers (ECOFIN) reached political agreement on, among other things, the inclusion of a general anti-abuse rule in the…

Dear FS professional, This is the final newsletter for 2014. As mentioned in the October FS Tax Newsletter the Skandia judgment may have a significant impact on financial service…

Every month we publish an e-newsletter which gives you an overview of international tax developments being reported globally by KPMG member firms in the American, Africa, Europe and ASPAC…

Meijburg & Co has been ranked 'Tier 1' in the recently published ITR World Tax 2015. CLICK HERE FOR THE COMPLETE GUIDE WITH LEADING TAX FIRMS  Meijburg has also been ranked…

Ireland’s Finance Minister Michael Noonan announced that the Irish rules on corporate tax residence would be changed so that all companies incorporated in Ireland are tax resident in…

Tax laws across Europe are undergoing massive reforms with one key component being the ongoing work of the Organisation for Economic Co-operation and Development (OECD) and their Base…

Dear FS professional, The FS Tax Newsletter of KPMG Meijburg & Co was introduced in April 2012 and is published every two months. The FS Tax Newsletter addresses recent…

According to this judgment, pension funds that operate a defined contribution plan (DC plan) can qualify, under certain conditions, as a common investment fund within the meaning of the VAT…

The Court of Justice of the European Union has ruled that services provided by a head office to a fixed establishment that is part of a VAT group are subject to VAT.…

On September 16, 2013, the OECD launched the first set of reports following its Action Plan to deal with base erosion and profit shifting (“BEPS”). The reports address 7 of the…

Every month we publish an e-newsletter which gives you an overview of international tax developments being reported globally by KPMG member firms in the American, Africa, Europe and ASPAC…

Every month we publish an e-newsletter which gives you an overview of international tax developments being reported globally by KPMG member firms in the American, Africa, Europe and ASPAC…

The new tax treaty between China and the Netherlands will enter into force at the end of August and apply to income received after January 1, 2015. A number of changes that have been made…

Now that the end of the summer is approaching, why not ease back into business with some light reading in the form of our FS Tax Newsletter. The main topic this time is the introduction of…

The Court of Justice of the European Union held that a Danish provision for recapture of losses sustained in a foreign permanent establishment constitutes a restriction of the freedom of…

KPMG’s Taxation of Cross-Border Mergers and Acquisitions features information from 60 countries on their current laws and regulations and the potential implications for tax-efficient…

Dear FS Tax professional, As indicated in our last FS Tax newsletter, we hereby provide you with a separate FS Indirect Tax Newsletter. Also, in the FS Indirect Tax arena there is a number…

Every month we publish an e-newsletter which gives you an overview of international tax developments being reported globally by KPMG member firms in the American, Africa, Europe and ASPAC…

On June 10, 2014 the new bilateral rules for the avoidance of double taxation between the Netherlands – including the Caribbean part – and Curaçao (“BRNC”) were announced and…

The amendment means that payments received on cross-border hybrid loans will be excluded from tax exemption as from January 1, 2016.…

On June 12, 2014 the Court of Justice of the European Union (CJEU) ruled that Dutch legislation on the fiscal unity for corporate income tax purposes is contrary to the European freedom of…

Every month we publish an e-newsletter which gives you an overview of international tax developments being reported globally by KPMG member firms in the American, Africa, Europe and ASPAC…

The Court of Justice of the European Union in Luxembourg has concluded that the 8.3% dividend withholding tax pursuant to the BRK is permissible subject to certain conditions. …

The Association of Southeast Asian Nations (ASEAN), including Brunei Darussalam, Cambodia, Indonesia, Lao PDR, Malaysia, Myanmar, Philippines, Singapore, Thailand and Vietnam, is rapidly…

The District Court in The Hague recently rendered judgment in a case concerning the recharging of advisory fees by a bank. The bank had deployed an external advisor in connection with the…

The Advocate General concludes that transactions between a foreign head office and a fixed establishment that is part of a VAT group are outside the scope of VAT.…

Indirect and corporate tax rates on a rollercoaster ride: KPMG International survey reviews the ups and downs…

On April 11, 2014, the Dutch Supreme Court provided guidance regarding on the treatment of tariff income for Dutch State Profit Share purposes.…

Every month we publish an e-newsletter which gives you an overview of international tax developments being reported globally by KPMG member firms in the American, Africa, Europe and ASPAC…

Dear FS professional, We are pleased to present you with the April issue of the FS Tax Newsletter. In this issue we look at the Capital Requirements Directive IV (which implements Basel…

Of the countries in Western Europe, the Netherlands is the most attractive for foreign companies wishing to locate in this part of Europe.…

On March 24, 2014, the OECD released a public discussion draft on the tax challenges of the digital economy, as part of its base erosion and profit-shifting action plan (Action 1).…

On March 20, 2014 Luxembourg has agreed to a proposed revision of the EU Savings Directive. This clears the path for the EU Council of Ministers to adopt the amendments in the Savings…

On 19 March 2014, the OECD released two public discussion drafts on the development of model treaty provisions and recommendations for the design of domestic rules to neutralize the effect…

Recently, the OECD issued a public discussion draft on tax treaty abuse as part of its base erosion and profit-shifting action plan.…

Every month we publish an e-newsletter which gives you an overview of international tax developments being reported globally by KPMG member firms in the American, Africa, Europe and ASPAC…

Via this alert we would like to inform you about the recently published ‘guidelines’ from the Swiss federal tax administration on the taxation of Principal Companies, which could have a…

Under Dutch legislation, a fiscal unity for corporate income purposes cannot be established between sister companies of a foreign parent, or between sister companies and the foreign parent.…

On February 7, 2013, the Supreme Court rendered judgment in two cases that dealt with whether a payment should be regarded as interest or as exempted participation dividend.…

This edition of our newsletter provides an update on developments in the financial services sector, such as the agreement signed by the US and the Netherlands with respect to FATCA and the…

On January 30, 2014, Ms. Van Hilten, the Advocate General attached to the Supreme Court, issued her independent opinion on the appeal a taxpayer had filed before the Supreme Court regarding…

Representatives of the Netherlands and the United States signed an intergovernmental agreement for the automatic exchange of data between the tax authorities of both countries, thus…

To improve the speed with which requests for the application of the catch all clause contained in tax treaties are dealt with, the Ministry of Finance has decided to transfer the processing…

The Supreme Court has requested preliminary rulings on Dutch dividend withholding tax levied on non-resident private shareholders and foreign companies.…

Dear FS professional, This is the final newsletter for 2013. The majority of issues discussed in this newsletter relate to increased regulation for financial institutions. CRD IV lays down…

Banks will be able to deduct, for tax purposes, the return on additional Tier 1 capital, even if it was issued after January 1, 2014.…

On December 12, 2013, the Netherlands and Curaçao reached agreement on a new tax regulation for the avoidance of double taxation between the two countries.…

An overview of the REIT regimes in Europe, Asia and the Americas.…

Every month we publish an e-newsletter which gives you an overview of international tax developments being reported globally by KPMG member firms in the American, Africa, Europe and ASPAC…

On Tuesday, November 26, 2013, the Deputy Minister of Finance released a new transfer pricing decree which brings Dutch policy on transfer pricing in line with recent developments in this…

On November 25, 2013, the European Commission proposed amendments to the EU Parent-Subsidiary Directive (“the Directive”) in order to close off perceived opportunities for corporate tax…

The Supreme Court has ruled that a Finnish investment fund is not entitled to a refund of withheld Dutch dividend withholding tax.…

KPMG Meijburg & Co. has been ranked 'Tier 1' in the recently published ITR World Tax 2014.…

On November 1, 2013, the Supreme Court requested a preliminary ruling from the Court of Justice of the European Union (CJEU) on the VAT treatment of the management of real estate…

On October 11, 2013, the Supreme Court ruled that payment and collection services provided to mortgage lenders are subject to VAT…

Under current legislation, acquisitions of interests of less than one third in real estate entities are not subject to real estate transfer tax, while acquisitions of one third or more are…

Fiscal investment institutions are subject to a 0% corporate income tax rate, provided they meet certain conditions. One of these conditions is that the fiscal investment institution only…

The advisors of Meijburg & Co’s Indirect Tax Financial Services group have extensive experience not only in identifying the VAT risks confronting institutional investors and their asset…

The advisors of Meijburg & Co’s Indirect Tax Financial Services group have extensive experience in identifying the VAT risks confronting financial institutions, but also the VAT…

The advisors of Meijburg & Co’s Indirect Tax Financial Services group have extensive experience in not only identifying the VAT risks confronting payment service providers, but also the…

Meijburg & Co’s Indirect Tax Financial Services Group advises clients active in the banking industry. Our specialists have extensive experience with identifying VAT risks, advising on…

The advisors of Meijburg & Co’s Indirect Tax Financial Services group have extensive experience in not only identifying the VAT risks associated with insurance products, but also the VAT…

Meijburg & Co’s Financial Services specialists have long provided tax advice to parties in the field of Investment Management. …

Meijburg & Co has long been a leader in providing tax advisory services to a large number of national and international financial institutions. This has enabled our advisors to gain…

On July 18, 2013, the Court of Justice of the European Union ("CJEU") rendered judgment in the PPG Holdings BV case (C-26/12) concerning the recovery of VAT charged on costs incurred by a…

On March 7, 2013, the Court of Justice of the European Union ("CJEU") rendered its judgment in the Wheels Common Investment Fund Trustees Ltd case (C-424/11) on the VAT position of the…

The European Commission’s proposal for an EU wide tax on financial transactions (FTT) has generated much public and political discussion since it was published on September 28,…

The bill foresees an amendment to the Tax Collection Act and provides for the possibility of deferring payment for corporate and personal income tax purposes. This article discusses in…

Source: NTFR 2012/2126, pages 7-13 Author(s): Bauco Suvaal Uncertainty exists in the tax practice, and possibly also in judicial circles if a recent judgment rendered by the District Court…

Every month we publish an e-newsletter which gives you an overview of international tax developments being reported globally by KPMG member firms in the American, Africa, Europe and ASPAC…