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.
A limited number of companies whose activities involve the extraction or refining of oil and gas (approximately 40) are expected to become subject to the solidarity levy.
In practice, large amounts in dividend tax are avoided via various forms of dividend stripping, which the Dutch tax authorities cannot properly combat with the legal instruments currently available to ...
In particular, the Supreme Court answered several outstanding questions about Section 10a Corporate Income Tax Act 1969, such as when is there an ‘intra-group (non-business motivated) diversion’.
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.
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 ...
