Transfer Pricing News

Transfer pricing and controversy

Organizations are increasingly finding themselves involved in tax disputes with tax authorities. This is happening in the Netherlands, but also elsewhere.Companies that operate at the international le ...

Final EU public CbCR guidance and form published

The European Commission (EC) on October 21, 2024, published an updated implementing regulation providing the common template and electronic reporting formats for the application of the EU public count ...

Follow up webinar Public Country-by-Country Reporting

We plan to delve deeper into these topics in our upcoming tax news flashes and the transfer pricing seminar in October 2024. Stay tuned for more detailed discussions and practical advice on navigating ...

Additional guidance on Amount B

All businesses, regardless of size, are potentially in the scope of Amount B if they carry out certain pre-defined distribution activities, as defined in the OECD Inclusive Framework’s Report of Febru ...

EU public Country-by-Country Reporting

On December 1, 2021 the EU public Country-by-Country Reporting (CbCR) Directive was published in the EU Official Journal and entered into force. The objective of the Directive is to create corporate t ...

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

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.

New policy statement on VAT fixed establishments

The policy statement, among other things, lays down the Dutch viewpoint on the concept of a fixed establishment and the VAT treatment of transactions between a head office and a fixed establishment.

New questions to CJEU: towards a broader concept of fixed establishment for VAT purposes?

A Romanian Court recently sought a preliminary ruling from the Court of Justice of the European Union (‘CJEU”) about the concept of fixed establishment for VAT purposes in the Berlin Chemie case (C-33 ...

CJEU in Dong Yang case: subsidiary could be a fixed establishment for VAT purposes

On May 7, 2020 the Court of Justice of the European Union (‘CJEU’) rendered judgment in the Dong Yang Electronics case (C-547/18). The case concerned whether a subsidiary may, for VAT purposes, consti ...

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