Category: Blogs
Tax function and software as a solution for transfer pricing and more
When I started my career as tax manager of a listed MNE, transfer pricing topics were only for the happy few. In those years I was already often consulted on this topic by colleagues of other MNEs and was asked “how to handle transfer pricing”. Th...
When I started my career as tax manager of a listed MNE, transfer pricing topics were only for the happy few. In those years I ...
Read more
Banks may request a substantiation of your transfer pricing: be prepared!
Recently the Dutch Central Bank published a guideline for banks titled “Good practices tax integrity risks with clients of banks”. These good practices include an analysis of clients’ intercompany transactions, with a substantiation of the transfe...
Recently the Dutch Central Bank published a guideline for banks titled “Good practices tax integrity risks with clients of bank...
Read more
Mandatory Disclosure rules: time to act now!
MNEs will have to develop a policy In 2018, the EU adopted new minimum rules for the disclosure of potentially aggressive cross-border tax planning arrangements. EU Member States have to implement these rules in their domestic legislation on 31 De...
MNEs will have to develop a policy In 2018, the EU adopted new minimum rules for the disclosure of potentially aggressive cross...
Read more
OECD and Brazil share outcomes of project to align Brazil’s transfer pricing rules to OECD standard
Brazil and the OECD have been working together for the past 15 months to see whether a closer alignment between the TP system of Brazil and the OECD guidelines is possible. A joint statement of the outcomes was made public on July 11, 2019. Work p...
Brazil and the OECD have been working together for the past 15 months to see whether a closer alignment between the TP system o...
Read more
Implementation renewed Dutch ruling practice
As per 1 July 2019, a new Decree on international tax rulings [1] (including Advance Pricing Agreements and Advance Tax Rulings), entered into force. The Decree of 19 June 2019 replaces the previous Decrees of 3 June 2014. However, rulings signed ...
As per 1 July 2019, a new Decree on international tax rulings [1] (including Advance Pricing Agreements and Advance Tax Rulings...
Read more
Proposed new policy Dutch ruling practice – What’s new?
On 23 April 2019, the new proposed Decree on international tax rulings (including Advance Pricing Agreements and Advance Tax Rulings) was published by the Dutch Secretary of State for Finance. It is intended that the new Decree will be implemented...
On 23 April 2019, the new proposed Decree on international tax rulings (including Advance Pricing Agreements and Advance Tax Ru...
Read more
£107 million Diverted Profit Tax charge to Diageo: Is it a tax?! Is it a penalty?! Or is it proof that HMRC has superpowers…
On May 10, Diageo, a FTSE 100 alcoholic beverage company, reported that it will have to pay a Diverted Profit Tax charge of £107 million in relation to a period of just 15 months. This evidences the approach HMRC is taking in inquiries where it do...
On May 10, Diageo, a FTSE 100 alcoholic beverage company, reported that it will have to pay a Diverted Profit Tax charge of £10...
Read more