International tax disputes – mutual agreement procedures and arbitration

Multinationals krijgen soms te maken met een internationaal fiscaal geschil. Een voorbeeld van een internationaal fiscaal geschil is als de fiscus van het ene land transfer pricing-correcties voor grensoverschrijdende transacties oplegt zonder dat daar in het andere land correcties tegenover staan. Wij leggen graag uit hoe wij omgaan met internationale fiscale geschillen.

Sometimes, multinational enterprises find themselves faced with double taxation. E.g. when the tax authorities of one state impose transfer pricing adjustments for cross-border transactions without corresponding adjustments being made in the other state.

Double taxation

Double taxation is not limited to just the transfer pricing realm. Differences in how some states interpret tax treaty provisions, income or other qualifications will also lead to double taxation. While double taxation typically involve corporate profit taxes, they may also concern other taxes.

Resolving international tax disputes

Resolving international tax disputes often requires the cooperation of tax authorities in two or more states. In that case, a Mutual Agreement Procedure (MAP) or arbitration is the way forward.

Contact Meijburg for tax disputes?

Our specialists would be pleased to help you with cross‑border tax disputes and tax proceedings. If you have any questions or would like to discuss tax disputes and tax proceedings please call Aldo Mariani or Tom Noë.

Interview: Internationaal fiscaal geschil

Lees hier het interview!
Aldo Mariani
Aldo Mariani
Partner

Aldo is a highly experienced tax lawyer who has provided tax services to a multitude of clients over the past 30 years. His main area of focus is international corporate income tax. As an attorney-at-law, he assists clients who have a dispute with the tax authorities, both in and outside the Netherlands. Aldo specializes in resolving complex tax issues, offering both subject matter expertise and ethical, tactical and strategic input. Aldo is also Head Global Tax Dispute Resolution & Controversy Services.

mariani.aldo [at] kpmg.com Amstelveen
JLK
mr. J. (Jens) Lamberg Karreman
Partner

Jens has over 29 years of experience in the field of taxation. He currently works in Meijburg & Co’s international corporate income tax and transfer pricing practices. Jens began his career at the Dutch Tax and Customs Administration, where he held a variety of positions. He was a member of the Dutch Revenue's APA/ATR team in Rotterdam, where he specialized in international structures and related transfer pricing issues. He left the Dutch Tax and Customs Administration to join Meijburg & Co in 2005. Jens focuses on tax and transfer pricing disputes in a national and international context, making use of available dispute resolution instruments such as APA’s, ATR’s, mutual agreement procedures (MAPs), bilateral investment treaties (BITs),  joint audits and of his extensive network. Jens has a Law Degree from Tilburg University and is a member of the Dutch Association of Tax Advisors.

karreman.jens [at] kpmg.com Amstelveen
Tom Noe
Tom Noë
Senior Manager

Tom has worked at KPMG Meijburg & Co since 2008. He has extensive experience in assisting clients in tax audits, particularly when fines and penalties can be expected or are being imposed. Tom helps clients to meet their national and international information provision obligations to tax authorities, and devises strategies for businesses on how to go about the international exchange of information.

noe.tom [at] kpmg.com Amstelveen

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