Transfer Pricing

Group company not a fixed establishment for VAT purposes, but CJEU has left the door open

The CJEU provided more guidance on the circumstances in which the human and technical resources of an independent legal entity could result in a separate fixed establishment.
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Good Practices Tax Control Framework: next steps

In its webinar on January 13, 2022, the Dutch Tax and Customs Administration, in collaboration with the Dutch Association of Tax Advisors, provided further details on the background to the Good Practi...
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Good Practices Tax Risk Management

Praktijkvoorbeelden om een globaal beeld te geven van hoe een organisatie kan omgaan met verschillende elementen van het Tax Control Framework (TCF).
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Year end 2021 tax accounting considerations

As the end of the year is fast approaching, many organizations will soon start preparing their year end financial statements. The announced 2022 Tax Plan may have a significant impact on those financi...
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Without own staff, no fixed establishment for VAT purposes in the case of let property

On June 3, 2021 the Court of Justice of the European Union (‘CJEU’) rendered judgment in the Titanium Ltd case (case no. C-931/19). The CJEU ruled that a foreign taxable person that does not have its ...
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Mismatches in non-arm’s length transfer pricing tackled

On March 4, 2021 a public internet consultation was launched on a bill to combat mismatches when applying the arm’s length principle. The bill focuses on informal capital arrangements.
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New policy statement on VAT fixed establishments

The policy statement, among other things, lays down the Dutch viewpoint on the concept of a fixed establishment and the VAT treatment of transactions between a head office and a fixed establishment.
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