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Clarification of anti-transfer pricing mismatch rule in the case of capital contributions

January 24, 2023
On January 24, 2023 Deputy Minister of Finance Mr. Van Rij clarified in a policy statement the scope of one of the measures to combat transfer pricing mismatches.
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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 ...
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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.
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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.
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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 ...
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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 ...
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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.
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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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Good Practices Tax Risk Management

December 17, 2021
Praktijkvoorbeelden om een globaal beeld te geven van hoe een organisatie kan omgaan met verschillende elementen van het Tax Control Framework (TCF).
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Year end 2021 tax accounting considerations

November 12, 2021
As the end of the year is fast approaching, many organizations will soon start preparing their year end financial statements. The announced 2022 Tax Plan may have a significant impact on those financi ...
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Without own staff, no fixed establishment for VAT purposes in the case of let property

June 22, 2021
On June 3, 2021 the Court of Justice of the European Union (‘CJEU’) rendered judgment in the Titanium Ltd case (case no. C-931/19). The CJEU ruled that a foreign taxable person that does not have its ...
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Mismatches in non-arm’s length transfer pricing tackled

March 5, 2021
On March 4, 2021 a public internet consultation was launched on a bill to combat mismatches when applying the arm’s length principle. The bill focuses on informal capital arrangements.
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