Dutch Supreme Court judgment on the crediting of dividend withholding tax

On January 19, 2024 the Dutch Supreme Court clarified the rules applying to the crediting of dividend withholding tax for corporate income tax purposes.

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Inflation and its impact on your transfer pricing

December 19, 2022

In many industries, rising prices are leading to reduced margins. How does that impact transfer pricing? This question is especially relevant if your company’s transfer pricing model is based on guara ...

CJEU annuls Commission decision on Luxembourg transfer pricing ruling

November 14, 2022

The decision of the Court of Justice of the European Union brings key clarifications with regard to the choice of a reference system in transfer pricing State aid reviews.

2022 Decree on Profit Attribution to Permanent Establishments

July 11, 2022

The most important changes are the incorporation of the results of the OECD’s BEPS project and the source exemption that was introduced into the Corporate Income Tax Act 1969 in 2012.

2022 Transfer Pricing Decree

July 5, 2022

The changes to the Decree are mainly a reaction to the changes made to the OECD guidelines in respect of financial transactions, intra-group services and recent OECD publications on the treatment of g ...

New Dutch Transfer Pricing Decree

July 1, 2022

The new Dutch Transfer Pricing Decree was published on July 1, 2022. The new decree focuses on recent developments that have resulted in changes to the OECD Transfer Pricing Guidelines but also ...

Group company not a fixed establishment for VAT purposes, but CJEU has left the door open

April 11, 2022

The CJEU provided more guidance on the circumstances in which the human and technical resources of an independent legal entity could result in a separate fixed establishment.

Good Practices Tax Control Framework: next steps

January 13, 2022

In its webinar on January 13, 2022, the Dutch Tax and Customs Administration, in collaboration with the Dutch Association of Tax Advisors, provided further details on the background to the Good Practi ...

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