Are you losing money because of Tax Equalization? – Tax Technology offers you insight!
A common agreement in the world of cross-border employment is the ‘tax equalization agreement’ between an employer and employee. Under this agreement, an employee does not pay more or less tax during their secondment than the tax they would have paid had they continued to live or work in their home country.
Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting signed by the Netherlands and other countries
On June 7, 2017, the Dutch Minister of Finance Dijsselbloem and other high-level representatives of 67 countries representing 68 jurisdictions signed the Multilateral Convention (“Multilateral Instrument” or “MLI”) to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting (BEPS) and improve dispute resolution mechanisms.
Dutch Lower House of Parliament passes Bill on ratification of the MLI
On February 12, 2019 the Dutch Lower House of Parliament passed the Bill for the ratification of the Multilateral Convention (“MLI”) to Implement Tax Treaty-Related Measures to Prevent Base Erosion and Profit Shifting (BEPS) and improve dispute resolution mechanisms. Noteworthy is that the Lower House also agreed to change the MLI position of the Netherlands with respect to preventing the artificial avoidance of permanent establishment status.
“An aging population and digitization are eroding the tax base.”
A digitizing economy and an aging population are creating financial problems for governments and forcing them to look at the financing of public expenditure over the longer term. In other words, the sources of taxation. What is the solution? Robert van der Jagt, partner at KPMG Meijburg & Co, explains.
“In a digital world, we don’t just tax profits in the country where a business has a physical presence.”
Most international businesses pay taxes via local offices (permanent establishments) on profits they realize in other countries. But in today’s digital economy there is often no such thing as a permanent establishment, despite the fact that products and services are sold in several countries, and customers create information that is valuable. Should the country where the customers are located therefore not also be able to tax part of the profits? Michael van Gijlswijk, partner at KPMG Meijburg & Co, explains these developments in more detail.
“Consumers are now digital resources that are mined without being paid for.”
The current tax system is no longer adequate because it is not designed for digital business models like Airbnb, Uber, or Amazon. This gives rise to international tax debates, which sometimes raise the question whether we should fall back on ‘old-fashioned’ tax systems. Digital technology, the virtual presence, is new. However, the fundamental cornerstone of taxation - where profits are realized - is not. Even in the Dutch colonial era, a pertinent question was which part of the profits of multinationals could be attributed to the Dutch East Indies and taxed there. Fred van Horzen, partner at KPMG Meijburg & Co, explains.