Tax controversy

Tax Controversy & Amount B: more uncertainty?

What is the potential impact on your organization in terms of Tax Controversy and Tax Dispute management if in January 2024 other prices for baseline marketing and distribution activities were to fall ...

Amendment ruling policy

On July 6, 2023 a letter was sent to the Lower House of Parliament in which the Deputy Minister of Finance announced that he intends to amend / relax the ruling policy as of the beginning of October 2 ...

Don’t always pursue a ruling, but always consider one

Where the ruling practice used to be seen as a fundamental pillar of the Dutch business climate, the Dutch tax authorities now describe preliminary consultation as ‘an important element of its monitor ...

Bilateral APAs and mutual agreement procedures (MAPs): why the interest due may differ

Interest on tax due and late payment interest also often play a role in the adjustment or reassessment of the profit. Sates involved maintain different national rules on interest, which can result in ...

Legal protection under Pillar II - or more to the point: the absence of it

As of 2024, the Pillar 2 rules will become a reality within the EU and other jurisdictions worldwide. Under Pillar 2, the Global Anti-Base Erosion (GloBE) rules ensure that large multinational enterpr ...

Aldo Mariani appointed as Head of Global Tax Dispute Resolution and Controversy Services network

Aldo Mariani has been appointed as Head of Global Tax Dispute Resolution and Controversy Services network

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 Mechani ...

Tax audits are becoming increasingly digital and data driven. Tax authorities worldwide are taking additional measures to assess the alignment between companies' operating models and their tax model. We have developed a three-pronged approach to provide y

Under the leadership of the OECD, countries around the world are working together to combat tax avoidance. The increased focus on tax avoidance has also stimulated many tax authorities to carry out mo ...

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