On Thursday June 11th, KPMG Meijburg & Cos transfer pricing team organized a webcast to share the first experiences regarding transfer pricing issues in the context of the COVID-19 crisis. We have gathered the most pressing issues and questions that arise under multinationals and formulated a practical two-step approach for companies to follow.
In the case of substantial interest holders who borrow more than EUR 500,000 from their company, it is proposed to tax the excess as income derived from a substantial interest. Home acquisition debt is excluded. The measure will apply for the first time for the calendar year 2023, one year later than originally planned.
On June 15, 2020, the fifth letter describing the progress made with respect to ‘working as a self-employed person’ was published. In this letter, the Minister of Social Affairs and Employment and the Deputy Minister of Finance inform the Lower House of Parliament of the developments and the follow-up steps with regard to the measures in the field of self-employment.
The European Court of Justice ruled that a price discount leads to an adjustment of the recipient’s VAT recovery, even in the absence of a (credit) invoice specifying the supplies to which the discount relates.
From a letter sent to the Lower House of Parliament on May 28, 2020, it appears that the government has further consulted with employer and employee organizations in response to Emergency package 2.0.
More than two months ago the government announced a number of emergency measures in its ‘Jobs and Economy emergency package’ letter to the Lower House of Parliament dated March 17, 2020. These measures were intended to mitigate the first acute and widespread shock resulting from the coronavirus and the crisis measures introduced in this respect. On May 20, 2020 the government announced – once again in a letter to the Lower House of Parliament – that various measures in the first emergency package (Emergency package 1.0) would be extended and supplemented with new measures (Emergency package 2.0).
By letter to the Lower House of Parliament dated May 20, 2020, the Minister of Social Affairs and Employment announced that the Temporary emergency bridging measure to retain jobs (Tijdelijke noodmaatregel overbrugging voor behoud van werkgelegenheid; NOW) as it applies to the period March through May 2020 would be amended for a third time.
On May 18, 2020 the ‘Building Blocks for a Better Tax System’ package was published. The reports, which together contain more than 1000 pages of text, have resulted in 169 detailed policy options on a large number of taxes, which can be used by a new government.