Dutch Lower House of Parliament passes Bill o...
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.…
Bill on the Fiscal Unity Emergency Repair Act...
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.…
VAT: Recovery right on the basis of cross-bor...
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).…
Insurance premium tax: CJEU decision on locat...
The case concerned insurance policies for M&A transactions and the CJEU judgment provides a welcome clarification.…
Draft bill on transparency of civil society o...
It is a very broadly worded bill and will potentially affect many foundations and associations.…
Internet consultation on implementation of Ma...
This Directive provides for the mandatory automatic exchange of information on reportable cross-border arrangements.…
Dutch Supreme Court renders important judgmen...
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.…
VAT exemption on individual investment manage...
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…
ECOFIN discusses new French-German proposal f...
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…
Deputy Minister outlines main features of upd...
The proposed measures cover the elements transparency, process and content in the context of the issuing of all rulings with an international character.…
Lower House adopts 2019 Tax Plan package and...
We have summarized the adopted amendments and the most important adopted motions.…
CJEU: the purpose of the sale of shares may l...
The outcome of this judgment is of major importance for M&A practices, whether or not within groups, private equity enterprises, but also for operating businesses holding participations.…
Deputy Minister answers questions about emerg...
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.…
Public consultation on Bill implementing ATAD...
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.…
Country-by-Country Reporting: overview of not...
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.…
New developments regarding the 2019 Tax Plan...
On October 26, 2018, the Memoranda of Amendment resulting from the government’s reconsideration of the business climate package were also published.…
Partial VAT recovery for costs related to hir...
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).…
Dutch Supreme Court follows Court of Justice...
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…
CJEU: VAT recovery also permissible for unsuc...
On October 17, 2018, the Court of Justice of the European Union rendered judgment in the Ryanair case (C-249/17).…
Letter from Deputy Minister on reconsideratio...
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…
VAT: Cross border pro rata applies to costs i...
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…
FS Tax Newsletter Issue 35 | October 2018
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…
Internet consultation on tax treaty policy an...
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.…
Tax measures for 2019
The main features of the 2019 Tax Plan are addressed in our memorandum.…
Advocate General at CJEU: VAT recovery limita...
This Opinion is particularly important for M&A practices, whether or not within groups, private equity enterprises, but also for operating businesses holding participations.…
OECD discussion draft on the transfer pricing...
The discussion draft identifies the areas of disagreement between countries and solicits stakeholder input on these topics.…
European Commission State aid decision in the...
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).…
No longer advance certainty for a standard se...
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…
Bill with emergency remedial measures for fis...
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.…
FS Tax Newsletter Issue 34 | June 2018
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…
New mandatory disclosure requirements for int...
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.…
Deputy Minister answers parliamentary questio...
The announced measures will drastically change the Corporate Income Tax Act in the coming years.…
Deputy Minister of Finance releases new Trans...
This decree particularly concentrates on aspects where the 2017 OECD Transfer Pricing Guidelines leave scope for domestic interpretation.…
Advocate General: VAT on strategic acquisitio...
The AG at the CJEU concluded that Ryanair may deduct the VAT on professional services for a strategic acquisition, even if the takeover is ultimately unsuccessful.…
VAT applies to loan under hire purchase agree...
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.…
International Tax Newsletter - March 2018
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…
Insurance premium tax: Request for a prelimin...
The case concerns insurance policies for M&A transactions and could affect many types of cross-border insurance policies.…
FS Tax Newsletter Issue 33 | April 2018
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…
International Tax Newsletter - February 2018
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…
VAT exemption not applicable on instruction t...
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.…
European Commission releases package on taxat...
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.…
The Multilateral Instrument (BEPS Action 15)
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.…
Political agreement reached on proposal for m...
This is the latest in a series of EU initiatives in the field of the automatic exchange of information in tax matters.…
Deputy Minister provides more insight into hi...
One letter contained his Tax Policy agenda, while the other elaborated on the first priority of this agenda: combating tax avoidance and tax evasion.…
Court of Justice of the European Union also a...
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.…
FS Tax Newsletter Issue 32 | February 2018
The first 2018 issue of our FS Tax Newsletter contains a regular update of recent developments within the Financial Services sector.…
International Tax Newsletter - January 2018
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…
International Tax Newsletter - November 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…
European Commission opens in-depth State aid...
The Commission will adopt a final decision at the end of the formal investigation.…
Supreme Court rejects fiscal unity between Du...
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…
FS Tax Newsletter Issue 31 | December 2017
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…
ECOFIN agrees on an EU list of non-cooperativ...
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…
International Tax Newsletter - October 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…
Update Dutch dividend withholding tax
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…
Opinion of Advocate General at the Court of J...
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.…
International Tax Newsletter - September 2017
A monthly overview of international tax developments being reported globally.…
Tax aspects of the coalition agreement Octobe...
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…
Coalition agreement 2017: partial abolition o...
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…
FS Tax Newsletter Issue 30 | October 2017
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…
European Commission State Aid Announcement -...
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.…
Is VAT on services deductible in the case of...
The Danish court recently requested a preliminary ruling from the CJEU in the C&D Foods Acquisition ApS case (C-502/17).…
VAT exemption for cost-sharing groups does no...
The CJEU’s ruling that the VAT exemption for cost-sharing groups does not apply to the financial and insurance sector is very important.…
European Commission communication on taxation...
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…
Tax measures for 2018
The main features of the 2018 Tax Plan are addressed in our memorandum.…
Bill on withholding obligation holding cooper...
The proposals are expected to have a significant impact on the use of cooperatives in international structures.…
International Tax Newsletter - August 2017
A monthly overview of international tax developments being reported globally.…
Negative interest: an initial assessment from...
With a negative interest rate, roles are reversed and debtors receive an interest payment from creditors.…
International Tax Newsletter - July 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…
New OECD Transfer Pricing Guidelines Issued
A new edition of 612 pages of the OECD Transfer Pricing Guidelines was published on July 10, 2017.…
Is VAT on professional services deductible if...
On May 12, 2017 the Supreme Court of Ireland requested the Court of Justice of the European Union (CJEU) to render a preliminary ruling in the Ryanair case (C-249/17).…
International Tax Newsletter - June 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…
Internet consultation on Anti-Tax Avoidance D...
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…
Innovation Box – approval by OECD
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.…
Innovation Box: approval by EU Code of Conduc...
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.…
European Commission issues proposal for manda...
The proposal goes beyond the recommendations of BEPS Action 12 and proposes a wide ranging exchange of information.…
Multilateral Convention to Implement Tax Trea...
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…
International Tax Newsletter - May 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…
FS Tax Newsletter Issue 29 | June 2017
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…
Proposal to extend VAT adjustment rules to ‘e...
The administrative burden will increase because investments have to be followed for longer.…
Proposed changes to dividend withholding tax...
The introduction of a dividend withholding tax obligation for holding cooperatives represents a significant tightening of the current rules.…
International Tax Newsletter - April 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…
VAT exemption for cost-sharing groups: CJEU j...
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…
US tax reform - Trump administration announce...
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.…
Country-by-Country Reporting – Additional rul...
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…
International Tax Newsletter - March 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…
Advocate General at CJEU issues Opinion on VA...
Contrary to other recent Opinions, the AG considered that the VAT exemption for cost-sharing groups does apply to the financial and insurance markets.…
FS Tax Newsletter Issue 28| April 2017
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…
International Tax Newsletter - February 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…
Supreme Court refers preliminary questions to...
We welcome the fact that the Supreme Court has decided to request a preliminary ruling.…
Advocate General at CJEU issues Opinions on a...
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.…
EU Anti-Tax Avoidance Directive 2: hybrid mis...
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’).…
Main points of consideration regarding new Du...
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.…
Global Compliance Management Services
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…
International Tax Newsletter - January 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…
FS Tax Newsletter Issue 27 | Februari 2017
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…
Implementation of EU Country-by-Country Repor...
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…
International Tax Newsletter - December 2016
Americas Europe & Africa Asia Pacific & MENASA …
CJEU rules that Denmark should also have gran...
The Court concluded that the disadvantageous difference in tax treatment infringes the EU principle of freedom of establishment.…
Deputy Minister of Finance explains proposed...
We would like to point out that the draft bill and the details of these rules have not been made public and will probably only become clear during the internet consultation in 2017.…
Management of pension funds with a defined be...
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…
International Tax Newsletter - November 2016
Americas Europe & Africa Asia Pacific & MENASA …
No agreement yet on EU Anti-Tax Avoidance Dir...
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…
FATCA update: Sponsored FFIs will need their...
As of January 1, 2017, a Foreign Financial Institution (“FFI”) that is a Sponsored Entity may no longer use the Global Intermediary Identification Number (“GIIN”) of its Sponsoring…
Parliament approves Bill on the Fiscal Unity...
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…
Supreme Court limits VAT exemption for the ma...
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…
FS Tax Newsletter Issue 26 | December 2016
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…
Country-by-Country Reporting: extension of no...
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…
International Tax Newsletter - October 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…
Commission Package on Common (Consolidated) C...
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…
International Tax Newsletter - September 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…
FS Tax Newsletter Issue 25 | October 2016
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…
International Tax Newsletter - August 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…
International Tax Newsletter - july 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…
Tax measures for 2017
The main features of the 2017 Tax Plan are addressed in our memorandum.…
Proposed changes to Dutch dividend withholdin...
These changes include a withholding obligation for holding cooperatives, and the extension of an exemption for both shareholders and members of cooperatives in active business structures.…
EU Commission opens in-depth State aid invest...
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.…
OECD BEPS Action Plan - Taking the pulse in t...
The OECD Action Plan on BEPS, first introduced in 2013, set 15 specific action points to ensure international tax rules are fit for an increasingly globalized, digitized business world and…
Advocate General issues Opinion on VAT exempt...
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.…
EU Commission: Ireland gave illegal State aid...
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.…
International Tax Newsletter - june 2016
The e-newsletter is designed to be a one-stop shop for important news. The June 2016 edition is out.…
Dutch Lower Court requests Supreme Court to r...
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…
Opinion of Advocate General: Pension fund is...
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.…
Important judgments for corporate income tax;...
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…
International Tax Newsletter - May 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…
CJEU decision in the Riskin and Timmermans ca...
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…
Brexit: the tax consequences of the UK refere...
We give an overview of the tax consequences and shortly address the impact for the Netherlands as regards direct taxes.…
Political agreement on anti-tax avoidance dir...
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.…
Processing of debit and credit card payments...
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.…
Meeting of ECOFIN, no agreement on draft anti...
The matter has been postponed until the next ECOFIN meeting.…
Dutch government launches consultation on pro...
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.…
Commission issues notice on the notion of Sta...
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…
Advocate General concludes that Denmark does...
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 a fiscal unity betwee...
Court of Appeals allows fiscal unity between Dutch sister companies even if the parent company is established in a country outside the European Union.…
New policy statement on requests for the refu...
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.…
Commission announcement on public Country-by-...
With the exception of some changes, the final proposal does not deviate significantly from the circulated draft.…
EU Tax Law app eng
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,…
EU Commission proposes public Country-by-Coun...
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.…
CJEU: separate claim handling by third partie...
On March 17, 2016 the Court of Justice of the European Union (CJEU) ruled in the Polish Aspiro case (case no. C-40/15) that claim handling services are subject to VAT if these are performed…
ECOFIN reaches political agreement on non-pub...
This is a first step towards the formal adoption of the European Commission’s proposal.…
Supreme Court renders final judgments in the...
The Supreme Court ruling is favorable for foreign individuals with shares in Dutch companies.…
European Commission presents its new Anti-Tax...
The new package not only aims at implementing, in a coordinated manner, the OECD standards at the EU level, but goes beyond these recommendations.…
Section 13l and the Fiscal Unity Amendment Ac...
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…
EU Commission announces a final decision on i...
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…
New transfer pricing documentation rules enac...
The rules governing transfer pricing documentation including Country-by-Country Reporting, Master File and Local File are effective as of January 1, 2016.…
Cabinet response to the Initiative Memorandum...
The amendments will, at the earliest, be included in the 2017 Tax Plan, which will be presented on Budget Day 2016.…
CJEU judgment may have a major impact on the...
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…
10 EU Member States agree on some principles...
Estonia has indicated that it no longer supports the proposal.…
FS Tax Newsletter Issue 23 | December 2015
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…
Draft Implementation Decree on the Identifica...
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’.…
The Netherlands will appeal against the EU Co...
On 27 November 2015 the Netherlands announced it will appeal against the EU Commission’s decision in the State Aid case.…
Provision of market data and supply of techni...
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…
Decree approving ATRs: modification possible...
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.…
International Tax Newsletter - September 2015
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…
Ratification completed: new tax treaty with G...
As expected, the tax treaty with Germany has been ratified, which means that it will apply as of January 1, 2016.…
EU Commission announces final decisions on st...
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…
Pension fund is entitled to deduct the VAT on...
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…
European Ministers agree to exchange informat...
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.…
FS Tax Newsletter Issue 22 | October 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…
OECD releases final BEPS Package
The release of the final recommendations does not mean that the book on BEPS can now be closed.…
International Tax Newsletter - August 2015
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…
Lower House approves new tax arrangement betw...
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,…
CJEU decision in the joined cases Miljoen, X,...
The CJEU concluded that the Dutch withholding tax on non-resident portfolio individual and corporate shareholders is contrary to EU law if the tax burden on the non-resident is greater than…
CJEU decision in the Groupe Steria case
The decision offers possibilities for claiming, in cross-border situations, certain benefits available under the Dutch fiscal unity regime in domestic situations.…
The Lost Decree
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,…
FS Tax Newsletter Issue 21 | August 2015
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…
International Tax Newsletter - June 2015
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…
CJEU: warranty may be VAT-exempt insurance
In this case, the CJEU broadly interprets the VAT exemption for insurance.…
Supreme Court decision July 10, 2015 on Luxem...
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.…
Summary of BEPS Action Plan and Status as per...
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…
Opinion AG CJEU in the joined cases Miljoen,...
The AG concluded that withholding tax imposed on a non-resident may not exceed the individual income tax burden of a resident taxpayer.…
European Commission adopts Action Plan on cor...
As foreseen, this includes a proposal to re-launch the Common Consolidated Corporate Tax Base (CCCTB).…
International Tax Newsletter - May 2015
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…
EU Court of Justice decides that non-deductib...
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.…
OECD releases Country-by-Country (CbC) Report...
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…
State Aid - Commission Decision to open forma...
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.…
OECD - Discussion draft, BEPS Action 8 (hard-...
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…
FS Tax Newsletter Issue 20 | June 2015
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 at CJEU: VAT-exempt manageme...
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.…
Revised discussion draft on BEPS Action 6 (Pr...
The revised discussion draft deals with issues relating to the Limitation on Benefits provision, the Principal Purpose Test and several other issues.…
New tax treaty between the Netherlands and Ge...
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…
International Tax Newsletter - April 2015
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…
Clarity on Commodities Trading: Transforming...
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…
OECD releases Discussion Draft on Cost Contri...
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).…
International Tax Newsletter - march 2015
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…
OECD releases discussion draft on strengtheni...
On April 3, 2015, the OECD released a discussion draft which deals with BEPS Action 3: strengthening CFC rules.…
FS Tax Newsletter Issue 19 | April 2015
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…
EU proposes compulsory exchange of informatio...
The proposals are part of a package of measures to combat tax avoidance and harmful tax competition.…
International Tax Newsletter - February 2015
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…
Opinion issued in the PPG Holding BV case
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…
Dutch Tax and Customs Administration experien...
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…
Ministry of Finance’s position on impact of S...
According to the Ministry of Finance, the Skandia judgment does not apply in the Netherlands.…
International Tax Newsletter - January 2015
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…
Advocate General at the Court of Justice of t...
The case is important for the scope of the insurance exemption for VAT purposes.…
Supreme Court maintains 8.3% dividend withhol...
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…
FS Tax Newsletter Issue 18 | February 2015
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…
US business tax proposals
The proposed change in taxation of the foreign earnings of US companies, from a system of deferral into a minimum tax on a current basis, is a response to the offshore accumulation of…
Captive insurance companies: not insured for...
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…
The Financial Transaction Tax (FTT) – update...
Ministers of 10 EU Member States issued a joint statement to give a fresh impetus to a financial transaction tax (FTT).…
Dutch Guidance on FATCA Published
On Thursday 22 January 2015 the highly anticipated Dutch guidance on the Foreign Account Tax Compliance Act (“FATCA”) was published by the Dutch Ministry of Finance. This…
Dutch Tax Authorities focuses on entitlement...
The Dutch Tax Authorities have recently been pro-actively approaching holding and financing companies to question their entitlement to deduct VAT.…
International Tax Newsletter - December 2014
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…
EU Commission publishes decision on its state...
The decision sets out the factual and legal basis for the Commission’s preliminary view that one of these rulings constitutes state aid.…
New policy statement for fiscal unity between...
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…
OECD releases discussion draft on interest de...
On December 18, 2014, the OECD released a discussion draft which deals with BEPS Action 4: interest deductions and other financial payments.…
European Commission announces large-scale sta...
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…
Court judgments on fiscal unity between siste...
On December 17, 2014 the Deputy Minister of Finance announced that the three judgments would not be appealed before the Supreme Court.…
International Tax Newsletter - November 2014
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…
European Council of Ministers nearing agreeme...
More is now known about what was discussed by the ECOFIN on December 9, 2014 about the future of the European patent box regimes.…
Court of Appeals Amsterdam: fiscal unity betw...
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…
European Council of Ministers approves genera...
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…
FS Tax Newsletter Issue 17 | December 2014
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…
International Tax Newsletter - September 2014
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…
ITR World Tax Review 2015
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 announces changes to company residenc...
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…
OECD BEPS Action Plan
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…
FS Tax Newsletter Issue 16 | October 2014
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…
Letter from the Deputy Minister of Finance on...
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…
Judgment in Skandia America Corporation (C-7/...
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.…
OECD releases first recommendations action pl...
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…
International Tax Newsletter - August 2014
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…
International Tax Newsletter - July 2014
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…
New tax treaty between China and the Netherla...
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…
FS Tax Newsletter Issue 15 | August 2014
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…
European Court of Justice rules against Danis...
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…
Taxation of Cross-Border Mergers and Acquisit...
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…
FS Indirect Tax Newsletter | July 2014
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…
International Tax Newsletter - June 2014
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…
New Tax Regulation between the Netherlands an...
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…
EU Council of Ministers agrees with amendment...
The amendment means that payments received on cross-border hybrid loans will be excluded from tax exemption as from January 1, 2016.…
Court of Justice of the European Union rules...
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…
International Tax Newsletter - May 2014
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…
Important decision by CJEU on the dividend wi...
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. …
FS Tax Newsletter Issue 14 | June 2014
Dear FS Tax professional, Plenty of topics to think about in the summer, for a large part relating to Banking regulations. Tax has become an additional item in Banking supervision, and…
Decision Dutch District Court on VAT treatmen...
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…
Advocate General at CJEU issues Opinion on tr...
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.…
Corporate and Indirect Tax Rate Survey 2014
Indirect and corporate tax rates on a rollercoaster ride: KPMG International survey reviews the ups and downs…
Dutch State Profit Share – Recent Supreme Cou...
On April 11, 2014, the Dutch Supreme Court provided guidance regarding on the treatment of tariff income for Dutch State Profit Share purposes.…
International Tax Newsletter - March 2014
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…
FS Tax Newsletter Issue 13 | April 2014
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…
Competitive Alternatives, 2014 Edition
Of the countries in Western Europe, the Netherlands is the most attractive for foreign companies wishing to locate in this part of Europe.…
OECD issued public discussion draft on tax ch...
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).…
European Council agreed to adopt amendments t...
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…
OECD issued public discussion drafts on neutr...
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…
OECD issued public discussion draft on tax tr...
Recently, the OECD issued a public discussion draft on tax treaty abuse as part of its base erosion and profit-shifting action plan.…
International Tax Newsletter - February 2014
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…
Action required: new rules on Swiss Principal...
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…
Advocate General at Court of Justice of the E...
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.…
Tax Intelligence Solution
Do you want to identify your VAT risks and opportunities on time, based on facts, so that you can subsequently take appropriate action? And do you want to spare your IT colleagues a lot of…
Qualification capital contribution explained...
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.…
FS Tax Newsletter Issue 12 | February 2014
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…
Advocate General recommends further review on...
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…
Intergovernmental Agreement between Netherlan...
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…
Transfer of authority to deal with ‘catch all...
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 requests preliminary ruling...
The Supreme Court has requested preliminary rulings on Dutch dividend withholding tax levied on non-resident private shareholders and foreign companies.…
FS Tax Newsletter Issue 11 | December 2013
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…
Tax treatment of additional Tier 1 capital
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.…
Main features new tax regulation between the...
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.…
Taxation of real estate investment trusts
An overview of the REIT regimes in Europe, Asia and the Americas.…
International Corporate Tax Newsletter - Nove...
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…
Deputy Minister of Finance releases new trans...
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…
European Commission proposes amendments to Pa...
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…
Supreme Court rules against Finnish investmen...
The Supreme Court has ruled that a Finnish investment fund is not entitled to a refund of withheld Dutch dividend withholding tax.…
ITR World Tax 2014
KPMG Meijburg & Co. has been ranked 'Tier 1' in the recently published ITR World Tax 2014.…
Request for preliminary ruling from the Court...
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…
Services provided to mortgage lenders subject...
On October 11, 2013, the Supreme Court ruled that payment and collection services provided to mortgage lenders are subject to VAT…
Transfer Pricing Interpreter
Meijburg & Co Global Transfer Pricing Services has developed Interpreter. Using this software, your transfer pricing system can be documented as accurately as possible, in accordance with…
Transfer Pricing Documentation Solution
The Transfer Pricing Documentation Solution of Meijburg & Co Global Transfer Pricing Services offers companies an efficient tool for meeting the Dutch statutory documentation requirements.…
Recharging head office expenses
Using cutting-edge software applications, Meijburg & Co Global Transfer Pricing Services can produce a high-quality report that the Dutch Revenue and non-Dutch tax authorities generally…
Tax Plan 2014: acquisition of an interest of...
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 can − indirect...
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…
Indirect Tax – Investment management
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…
Indirect Tax – Financial services
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…
Indirect Tax – Payment Services
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…
Indirect Tax – Banking
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 Netherlands-United Kingdom Treaty for the...
The Dutch government has introduced a bank tax on the banking sector aimed at recovering the money lent as financial support to the banks during the financial crisis. This bank tax took…
Financial Services: Insurance
Meijburg & Co has for many years provided specialist tax advice to parties operating in the field of insurance, insurance brokerage, and insurance advisory services. We also specialize in…
Value Chain Management
Meijburg & Co advises businesses engaged in strategically transforming their national or international procurement, sales, production, service, or other processes. This may for instance…
Transfer Pricing
The tax authorities of OECD countries are becoming increasingly aware of how their tax proceeds are affected by the transfer prices multinationals use. As a result, national transfer…
Companies can recover the VAT charged on cost...
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…
OECD launches action plan on base erosion (BE...
On July 19, 2013, the OECD presented an action plan to deal with 'base erosion and profit shifting' (BEPS). In ournews item of January 2013 we already referred to the intentions in this…
The management of pension funds implementing...
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…
Financial Transaction Tax
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,…
Bill on deferral of payment of exit taxes
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…
Section 20a: the test moment tested
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…
FS Tax Newsletter (archive 2012 & 2013)
The Meijburg & Co Financial Services Tax Group is proud to present its FS Tax Newsletters. The FS Tax Newsletter is published every two months and addresses recent developments in FS…