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 pricing rules are becoming more stringent: tax authorities enterprises are demanding extensive documentation and can impose stiff penalties for failing to comply with these requirements. The same trend has been observed in the Netherlands.
How can Meijburg & Co assist you?
If your enterprise performs cross-border services or supplies, the question that automatically arises is whether the transfer prices used are at arm's length and whether they satisfy the documentation requirements in this respect. Meijburg & Co advises and supports you in addressing these questions, before, during, or after a confrontation with the Dutch Revenue. The following elements may play a role in this respect:
- designing, implementing, and documenting transfer pricing structures and models
- performing benchmark studies
- assessing whether documentation requirements are being met
- determining the value of assets and enterprises (or shares) for tax purposes
- setting prices upon the centralization of shared services/performing supply chain analyses
- providing support during audits, discussions with the Dutch Revenue, and dispute resolution
- concluding Advance Pricing Agreements (APAs) with the Dutch Revenue as a form of alternative dispute resolution
- handling tax litigation
With the release of the final report on BEPS 13 ‘Transfer Pricing Documentation and Country-by-Country Reporting’ by the OECD on 5 October, 2015, companies with cross-border operations (“MNEs”) are confronted with new transfer pricing documentation requirements. These proposed requirements will impact multinationals with a consolidated group turnover of EUR 50 million or more (globally). In order to provide cost effective, yet value adding insights and support to this group, as well as MNEs subject to these proposed documentation requirements, Meijburg & Co has developed service offerings which suit the individual situation of the MNE. Meijburg & Co can help you with the implementation as we have developed service offerings which suit the individual situation of the multinational. Please find our offerings in the flyers below this page.
How will you benefit?
Meijburg & Co will analyze the actual situation in your enterprise, your intended restructuring, and the relevant legislation. Based on these analyses, we will advise you on the actions that must be taken in order to achieve an optimum tax position. This entails ensuring the provision of correct documentation, avoiding the risk of double taxation, and, if so desired, obtaining advance certainty and mitigating your effective tax burden.
Why choose Meijburg & Co?
Our transfer pricing team is made up of economists, lawyers, accountants, and tax professionals with years of experience in this market sector. They devote their entire practice to this specialty. We work closely with experts in our corporate income tax and VAT groups, and this multidisciplinary approach enables us to offer you integrated solutions. The transfer pricing group is part of KPMG Global Transfer Pricing Services (GTPS) and employs full-time specialists in every OECD country. This affords you the security of knowing that our advice takes your overall tax position into account. You can also rely on the advice from the countries relevant to you being tailored together seamlessly to offer transfer pricing solutions that are a perfect fit for your enterprise.