Transfer Pricing

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-333/20). This case again shows that the concept of fixed establishment for VAT purposes is evolving.

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Impact of transfer pricing adjustments on EU customs valuation

Many companies are not aware that retrospective intercompany transfer pricing adjustments could potentially impact the customs valuation of goods imported into the EU. It is therefore imperative that action will be taken.

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Guidelines on Mandatory Disclosure Rules (DAC6) published

During the parliamentary debates on the Dutch implementation of the Mandatory Disclosure Rules (DAC6) it was acknowledged that, in practice, it can be difficult to determine whether or not a certain arrangement is reportable. The Guidelines for Reportable Cross-border Arrangements published on June 30, 2020 by Decree dated June 24, 2020, provide further details about the reporting obligation for ‘Dutch’ intermediaries or ‘relevant taxpayers’.

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Postponement of deadline for notifications under the Mandatory Disclosure Rules (DAC6)

Recently, agreement was reached at the EU level on postponing by six months the deadline(s) for notifying reportable cross-border arrangements to the Dutch tax authorities under the Mandatory Disclosure Rules (DAC6). By letter to the Lower House of Parliament dated June 26, 2020, the Deputy Minister informed the Lower House that he will also be granting a postponement in the Netherlands by way of a policy statement of the same date enclosed with that letter.

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Updated Decree on Mutual Agreement Procedures

The Decree provides, from a Dutch perspective, a detailed explanation and interpretation of the implementation of mutual agreement procedures (MAP’s) as regulated in the Tax Dispute Resolution Mechanisms Act (Wet fiscale arbitrage; WFA), the bilateral tax treaties and the EU Arbitration Convention.

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Transfer pricing in times of crisis: what should you do?

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.

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Transfer Pricing in the Corona Pandemic Disruption Era - an article by our experts

The onset of the Covid-19 pandemic has resulted in global business and economic disruptions with a direct impact on the transfer prices of multinational enterprises. Dianne Berry, Marcus Chadderton, and Eduard Sporken experts within our KPMG Global Transfer Pricing Services team, put their knowledge and expertise into an article for Bloomberglaw.com to look at what MNEs need to be doing to manage their transfer pricing arrangements.

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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, constitute a fixed establishment, and, if so, how the service provider must determine whether it performs its services to the parent company or the fixed establishment.

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Summary of report by the Advisory Committee on the Taxation of Multinationals

The Committee was asked to advise on measures to make the taxation of the profits of multinationals fairer, while at the same time ensuring that the Netherlands remains attractive for Dutch head offices.

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