Dutch Lower House of Parliament passes Bill o...
Noteworthy is that the Lower House also agreed to change the MLI position of the Netherlands with respect to preventing the artificial avoidance of permanent establishment status.…
Internet consultation on implementation of Ma...
This Directive provides for the mandatory automatic exchange of information on reportable cross-border arrangements.…
ECOFIN discusses new French-German proposal f...
On December 4, 2018, the Economic and Financial Affairs Council of the EU (ECOFIN) held an exchange of views on the digital services tax, but failed to reach an agreement on a compromise…
Deputy Minister outlines main features of upd...
The proposed measures cover the elements transparency, process and content in the context of the issuing of all rulings with an international character.…
Public consultation on Bill implementing ATAD...
On October 29, 2018, the government launched an internet consultation to give interested parties the opportunity to respond to the draft bill to implement ATAD2 to tackle hybrid mismatches.…
Country-by-Country Reporting: overview of not...
Meijburg & Co has prepared an overview of the CbCR notification requirements for all countries that implemented final CbCR legislation as of 2016, 2017 and 2018.…
OECD discussion draft on the transfer pricing...
The discussion draft identifies the areas of disagreement between countries and solicits stakeholder input on these topics.…
European Commission State aid decision in the...
On June 20, 2018, the European Commission announced its final decision on the state aid investigations into tax rulings granted by the Luxembourg tax authorities to GDF Suez (Engie).…
New mandatory disclosure requirements for int...
As a result of the broad definition of an intermediary, DAC6 does not solely target tax advisors but also many other service providers in the legal, financial and consultancy branches.…
Deputy Minister answers parliamentary questio...
The announced measures will drastically change the Corporate Income Tax Act in the coming years.…
Deputy Minister of Finance releases new Trans...
This decree particularly concentrates on aspects where the 2017 OECD Transfer Pricing Guidelines leave scope for domestic interpretation.…
European Commission releases package on taxat...
The package includes both interim measures, in the form of a 3% Digital Services Tax on revenues, and a long-term solution, introducing the concept of a digital permanent establishment.…
The Multilateral Instrument (BEPS Action 15)
Our two-pager gives you an overview of the key BEPS Actions the MLI focusses on implementing, how it will work, who it will affect and what the next steps should be.…
Political agreement reached on proposal for m...
This is the latest in a series of EU initiatives in the field of the automatic exchange of information in tax matters.…
Deputy Minister provides more insight into hi...
One letter contained his Tax Policy agenda, while the other elaborated on the first priority of this agenda: combating tax avoidance and tax evasion.…
European Commission opens in-depth State aid...
The Commission will adopt a final decision at the end of the formal investigation.…
FS Tax Newsletter Issue 31 | December 2017
This issue of our newsletter contains our regular update of recent developments within the Financial Services sector. This month we have included an update on the coalition plans to abolish…
FS Tax Newsletter Issue 30 | October 2017
This newsletter contains an update with respect to the Funds for Mutual Accounts and the UK Criminal Finances Act. This newsletter also includes a summary of the CJEU court ruling about the…
European Commission State Aid Announcement -...
On October 4, 2017, the European Commission announced its final decision on its state aid investigations into transfer pricing rulings granted by Luxembourg to the Amazon group.…
New OECD Transfer Pricing Guidelines Issued
A new edition of 612 pages of the OECD Transfer Pricing Guidelines was published on July 10, 2017.…
Internet consultation on Anti-Tax Avoidance D...
On July 10, 2017 the Deputy Minister of Finance, Mr. Eric Wiebes, published a document for internet consultation aimed at the introduction or amendment of a number of anti-tax avoidance…
European Commission issues proposal for manda...
The proposal goes beyond the recommendations of BEPS Action 12 and proposes a wide ranging exchange of information.…
Multilateral Convention to Implement Tax Trea...
The Multilateral Convention (“Multilateral Instrument” or “MLI”) is in accordance with Dutch policy to combat BEPS on a multilateral basis and the Netherlands has taken a pro-active…
FS Tax Newsletter Issue 29 | June 2017
Dear FS professional, This newsletter contains information about an important insight from the Dutch Supreme Court on interest deduction, three VAT-related topics and the new insurance…
US tax reform - Trump administration announce...
On April 26, 2017, US Treasury Secretary Mnuchin and US National Economic Council Director Cohn announced the “core principles” of President Trump’s plan for US tax reform.…
Country-by-Country Reporting – Additional rul...
On April 18, 2017 the Lower House adopted the bill on additional rules for the exchange of Country-by-Country reports. In addition to this, on April 6, 2017 the OECD published additional…
FS Tax Newsletter Issue 28| April 2017
Dear FS professional, In the FS Tax Newsletter, we provide you with an update on developments in the Financial Services sector. In this edition you will find, among others, a summary of…
EU Anti-Tax Avoidance Directive 2: hybrid mis...
On February 21, 2017 the EU Member States reached agreement on a Directive that will amend the Anti-Tax Avoidance Directive (Council Directive (EU) 2016/1164 of July 12, 2016, ’ATAD 1’).…
FS Tax Newsletter Issue 27 | Februari 2017
Dear FS professional, We hope that the New Year got off to a good start for everyone. In the FS field, right at the end of last year, the Supreme Court ruled that pension funds with…
Implementation of EU Country-by-Country Repor...
The bill makes it possible to automatically exchange the Country-by-Country report submitted by a Dutch-resident Reporting Entity to the Dutch tax authorities, with the competent tax…
No agreement yet on EU Anti-Tax Avoidance Dir...
According to the compromise text issued on December 2, 2016, the proposed amendments (that would take the form of a directive (‘ATAD 2’) to amend ATAD 1) would have extended the scope…
FS Tax Newsletter Issue 26 | December 2016
Dear FS professional, This issue of our newsletter contains our regular update of recent developments within the Financial Services sector. This month we have included an update on the…
Multilateral Convention to Implement Tax Trea...
More than 100 jurisdictions have concluded negotiations on a Multilateral Convention (or ‘multilateral instrument’) that is intended to implement certain tax treaty related aspects of…
Country-by-Country Reporting: extension of no...
On November 21, 2016 the Dutch Deputy Minister of Finance issued a policy statement granting Dutch subsidiaries of multinational enterprises (MNEs) which are subject to Country-by-Country…
Commission Package on Common (Consolidated) C...
On October 25, 2016 the European Commission published legislative proposals to relaunch its Common Consolidated Corporate Tax Base initiative, as well as new measures to combat hybrid…
EU Commission opens in-depth State aid invest...
On September 19, 2016 the EU Commission announced that it was opening an in-depth investigation into tax rulings granted by Luxembourg to GDF Suez.…
EU Commission: Ireland gave illegal State aid...
The state aid has now been determined to be incompatible with the internal market, and must be recovered (with interest) by the Irish authorities from the Apple group.…
Brexit: the tax consequences of the UK refere...
We give an overview of the tax consequences and shortly address the impact for the Netherlands as regards direct taxes.…
Political agreement on anti-tax avoidance dir...
The directive is intended to provide a minimum level of protection for the internal market and strengthen the average level of protection against aggressive tax planning.…
Meeting of ECOFIN, no agreement on draft anti...
The matter has been postponed until the next ECOFIN meeting.…
Commission issues notice on the notion of Sta...
The 68 page communication is intended to provide clarification on the key concepts relating to the notion of State aid as referred to in Article 107(1) TFEU and is available in full in the…
Commission announcement on public Country-by-...
With the exception of some changes, the final proposal does not deviate significantly from the circulated draft.…
EU Commission proposes public Country-by-Coun...
The proposal would require multinational groups with a total consolidated revenue of EUR 750 million to report either if they are EU parented or otherwise have EU subsidiaries or branches.…
ECOFIN reaches political agreement on non-pub...
This is a first step towards the formal adoption of the European Commission’s proposal.…
European Commission presents its new Anti-Tax...
The new package not only aims at implementing, in a coordinated manner, the OECD standards at the EU level, but goes beyond these recommendations.…
New transfer pricing documentation rules enac...
The rules governing transfer pricing documentation including Country-by-Country Reporting, Master File and Local File are effective as of January 1, 2016.…
The European Commission announces another Sta...
On December 3, 2015 the European Commission announced its decision to launch a State Aid investigation into tax rulings granted by Luxembourg.…
The Netherlands will appeal against the EU Co...
On 27 November 2015 the Netherlands announced it will appeal against the EU Commission’s decision in the State Aid case.…
EU Commission announces final decisions on st...
These decisions confirm the Commission’s preliminary view that the transfer pricing rulings granted by the Netherlands and Luxembourg to companies in two multinational groups involved…
European Ministers agree to exchange informat...
With this amendment, the EU is broadly in line with the final BEPS Action Plan, and particularly Action 5, which was published on October 5, 2015.…
BEPS Action Plan Action 10: Assure that Trans...
Key features of the final report - ‘Aligning Transfer Pricing Outcomes with Value Creation’ The report ‘Aligning Transfer Pricing Outcomes with Value Creation’…
OECD releases final BEPS Package
The release of the final recommendations does not mean that the book on BEPS can now be closed.…
Netherlands to adopt BEPS Action 13 based Cou...
The proposed CbC Reporting and documentation requirements constitute a ground breaking change from the current Dutch documentation requirements.…
Summary of BEPS Action Plan and Status as per...
This document provides for a summary and the status of the OECD Action Plan on Base Erosion and Profit Shifting (“BEPS”), as per June 2015. We will first summarize the recent…
OECD releases Country-by-Country (CbC) Report...
The CbC implementation package can assist jurisdictions with the effective local implementation of CbC Reporting and consists of model legislation and three model Competent Authority…
State Aid - Commission Decision to open forma...
The decision to open a formal state aid procedure is another indication that the Commission is continuing to challenge the transfer pricing tax practices of the EU Member States.…
OECD - Discussion draft, BEPS Action 8 (hard-...
The discussion draft explains the difficulties faced by tax authorities in verifying the arm’s length basis on which pricing is determined by taxpayers for transactions involving a…
Revised discussion draft on BEPS Action 7 (Pr...
In March 2015 the Working Party on Tax Conventions and Related Questions moved from a series of alternative options to one preferred proposal, which is contained in the revised discussion…
Revised discussion draft on BEPS Action 6 (Pr...
The revised discussion draft deals with issues relating to the Limitation on Benefits provision, the Principal Purpose Test and several other issues.…
OECD releases Discussion Draft on Cost Contri...
On 29 April 2015 the OECD published a public Discussion Draft on possible revisions to chapter VIII of the OECD Transfer Pricing Guidelines on cost contribution arrangements (CCA’s).…
OECD releases discussion draft on strengtheni...
On April 3, 2015, the OECD released a discussion draft which deals with BEPS Action 3: strengthening CFC rules.…
EU proposes compulsory exchange of informatio...
The proposals are part of a package of measures to combat tax avoidance and harmful tax competition.…
Agreement on implementation package for count...
On February 6, 2015 the OECD announced that the OECD and G20 countries had reached agreement on an implementation package for country-by-country reporting in 2016 and a related…
Captive insurance companies: not insured for...
Lower courts have recently ruled in favor of the Dutch Tax Authorities in combating captives. As a result of this, we have noticed that, in its audits, the Dutch Tax Authorities is…
EU Commission publishes decision on its state...
The decision sets out the factual and legal basis for the Commission’s preliminary view that one of these rulings constitutes state aid.…
OECD releases discussion draft on interest de...
On December 18, 2014, the OECD released a discussion draft which deals with BEPS Action 4: interest deductions and other financial payments.…
European Commission announces large-scale sta...
The announcement follows recent decisions by the European Commission to initiate formal state aid proceedings against Ireland, Luxembourg and the Netherlands with regard to tax rulings…
ITR World Tax Review 2015
Meijburg & Co has been ranked 'Tier 1' in the recently published ITR World Tax 2015. CLICK HERE FOR THE COMPLETE GUIDE WITH LEADING TAX FIRMS Meijburg has also been ranked…
OECD releases first recommendations action pl...
On September 16, 2013, the OECD launched the first set of reports following its Action Plan to deal with base erosion and profit shifting (“BEPS”). The reports address 7 of the…
Action required: new rules on Swiss Principal...
Via this alert we would like to inform you about the recently published ‘guidelines’ from the Swiss federal tax administration on the taxation of Principal Companies, which could have a…
Tax Intelligence Solution
Do you want to identify your VAT risks and opportunities on time, based on facts, so that you can subsequently take appropriate action? And do you want to spare your IT colleagues a lot of…
Transfer of authority to deal with ‘catch all...
To improve the speed with which requests for the application of the catch all clause contained in tax treaties are dealt with, the Ministry of Finance has decided to transfer the processing…
Deputy Minister of Finance releases new trans...
On Tuesday, November 26, 2013, the Deputy Minister of Finance released a new transfer pricing decree which brings Dutch policy on transfer pricing in line with recent developments in this…
ITR World Tax 2014
KPMG Meijburg & Co. has been ranked 'Tier 1' in the recently published ITR World Tax 2014.…
Transfer Pricing Interpreter
Meijburg & Co Global Transfer Pricing Services has developed Interpreter. Using this software, your transfer pricing system can be documented as accurately as possible, in accordance with…
Transfer Pricing Documentation Solution
The Transfer Pricing Documentation Solution of Meijburg & Co Global Transfer Pricing Services offers companies an efficient tool for meeting the Dutch statutory documentation requirements.…
Recharging head office expenses
Using cutting-edge software applications, Meijburg & Co Global Transfer Pricing Services can produce a high-quality report that the Dutch Revenue and non-Dutch tax authorities generally…
Transfer Pricing
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…