A review petition has been filed in the controversial most-favored-nation (MFN) judgment delivered by the Indian Supreme Court last month.Continue Reading
Netherlands
Transfer pricing news, BEPS news, and international tax news in Netherlands
English version of Dutch Transfer Pricing Decree available
The Dutch tax authority has released an unofficial English translation of the Transfer Pricing Decree 2022, which came into effect in July last year.Continue Reading
In Obama’s blacklist once, but leading fight against tax avoidance today: Dutch tax official
Netherlands may have been on Obama’s blacklist in 2009, but it now leads the fight against tax avoidance, Marnix van Rij, Dutch State Secretary for Tax Affairs has said.Continue Reading
Netherlands opposes UN international tax framework
The Dutch State Secretary of Finance, Marnix van Rij, has expressed the government’s concerns regarding the recent UN resolution to establish an international tax cooperation framework.Continue Reading
Netherlands publishes comments on draft Minimum Tax Rate Act
The Dutch government has published 15 responses to its public consultation on the draft Minimum Tax Rate Act, 2024.Continue Reading
Netherlands to tackle “remarkable” tax avoidance arrangements
The Dutch finance ministry has launched a new project to tackle “remarkable tax arrangements.”Continue Reading
Inter IKEA Group paid less corporate income tax in 2022
The amount of corporate income taxes paid by Inter IKEA Group decreased to EUR 322 million (EUR 398 million in the 2021 financial year). However, the total tax contribution increased slightly to EUR 1,996 million (EUR 1,916 million in the 2021 financial year).Continue Reading
Parity for All? Delhi High Court upholds trigger of MFN clause, bats for ‘common interpretation’ of Tax Treaties
By Aditi Sharma (Partner, Khaitan & Co, India) & Krutika Chitre (Principal Associate, Khaitan & Co, India)
The Delhi High Court in its recently pronounced decision in the case of Concentrix Services Netherlands BV WP (C) 9051/2020 and Optum Global Solutions International BV WP (C) 882/2021 invoked the ‘Most Favoured Nation’ (MFN) clause under the India-Netherlands double taxation avoidance agreement (Tax Treaty) and applied a reduced 5% withholding rate on dividend income paid by Indian companies to Dutch shareholders.
Netherlands publishes much-awaited DAC6 guidance
The guidance provides detailed explanations on cross-border arrangement, definitions of intermediaries and relevant taxpayers, and the main benefit test, among others.Continue Reading
No COVID support to companies that engage in tax avoidance, says Dutch government
Companies engaged in undesirable tax planning can apply for individual support if they satisfy two tax-related conditions concerning business location and transactions.Continue Reading
Netherlands mulling withholding tax on dividends paid to low tax jurisdictions
The measure will apply to financial flows to countries with a corporate tax rate of under nine percent and to countries on the EU blacklist, even if the Netherlands has a tax treaty with them.Continue Reading
Dutch tax authority publishes DAC6 guidance
The DAC6 reporting requirement will come into effect on July 1, 2020.Continue Reading
EU Commission urges Ireland, Netherlands, four others to tackle aggressive tax planning
The six member states are: Cyprus, Hungary, Ireland, Luxembourg, Malta, and the Netherlands.Continue Reading
Switzerland amending tax treaties with New Zealand, Netherlands, Norway, and Sweden
The protocols contain an anti-abuse clause.Continue Reading
Dutch tax rulings to Nike under EU Commission’s scanner
The Commission is looking into five tax rulings issued by the Dutch tax authority to Nike group companies in the Netherlands between 2006 to 2015.Continue Reading
New EU corporate tax avoidance rules enter into force
The new anti-abuse measures entered into force on January 1, 2019.Continue Reading
France, Germany propose new digital tax plan
France and Germany urged the EU Council to adopt the proposed digital services tax by March 2019.Continue Reading
Netherlands to Deny Tax Rulings to ‘Letterbox’ Companies
The author is Alex Hunter, Editor, TP News. He oversees and updates the publication and also regularly writes news stories about transfer pricing and international tax law. Alex is reachable at editor@transferpricingnews.com
Netherlands will be putting into place stricter requirements for the issue of international tax rulings by the end of June 2019.
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Mutual Agreement Procedure Statistics Published for 2017
The OECD on October 10 published its 2017 mutual agreement procedure (MAP) statistics covering 85 tax jurisdictions.
According to the 2017 MAP statistics, new transfer pricing MAP cases are up by 25 percent and other MAP cases by 50 percent. Anecdotal evidence suggests that the increase in new MAP cases is due to a range of factors including the effects of the new reporting framework and increased awareness of and expectations from taxpayers about MAP, the OECD noted.Continue Reading
Aruba Newest to Join BEPS Inclusive Framework
Aruba has now joined the OECD’s Inclusive Framework on base erosion and profit shifting (BEPS).
The Inclusive Framework on BEPS allows interested countries and jurisdictions to work with the OECD and Group of Twenty nations on monitoring the implementation of the BEPS proposals.Continue Reading
Grant Thornton Boosts Presence in Dutch Caribbean
In a significant expansion drive, Grant Thornton, leading audit, tax, and advisory firm, has added offices in Aruba, Bonaire, Curaçao, and St. Maarten, boosting its already wide presence in 13 locations across the Caribbean.Continue Reading
Franka Sturm Joins Houthoff’s Tax Practice as Counsel
Houthoff, one of the largest law firms in the Netherlands, has hired Franka Sturm as Counsel for the firm’s tax practice.
Sturm has over 13 years of experience as a tax specialist in international practice with a focus on M&A and oil and gas.
Before joining Houthoff, Sturm worked with the Dutch Tax and Customs Administration and with PwC as a Senior Tax Manager.
Selective Tax Advantage to Starbucks: EU Court Hears the Netherlands
The author is Alex Hunter, Editor, TP News. He oversees and updates the publication and also regularly writes news stories about transfer pricing and international tax law. Alex is reachable on email (editor@transferpricingnews.com) and by phone (+447808558597).
At a hearing of the General Court of the European Union on July 2, the Dutch Government put forward three points to demonstrate that it did not provide selective tax advantages to Starbucks in violation of the EU state aid rules.Continue Reading
MNEs Using Irish, Dutch Tax Systems to Avoid Tax: Commission Report
The author is Alex Hunter, Editor, TP News. He oversees and updates the publication and also regularly writes news stories about transfer pricing and international tax law. Alex is reachable on email (editor@transferpricingnews.com) and by phone (+447808558597).
In a first, the European Commission has stressed that tax rules in seven EU member states facilitate corporate tax avoidance by multinational enterprises (MNEs).Continue Reading
Netherlands Underlines Plan to Tackle Tax Avoidance
The author is Alex Hunter, Editor, TP News. He oversees and updates the publication and also regularly writes news stories about transfer pricing and international tax law. Alex is reachable on email (editor@transferpricingnews.com) and by phone (+447808558597).
In a 24-page long letter to the country’s Parliament, Dutch State Secretary for Finance, Menno Snel, has set out a detailed tax plan to tackle multinational tax avoidance, including measures to prevent the internationally-oriented Dutch tax system from being used as a conduit to tax havens.Continue Reading
The Future of the Dutch Tax Ruling Practice
By Jian-Cheng Ku (Legal Director, DLA Piper Nederland N.V.) and Jeroen Swart, (Tax Adviser, DLA Piper Nederland N.V.)
On February 18, 2018, the Dutch State Secretary of Finance announced that it will revise the Dutch tax ruling practice in light of results from a review conducted to examine if Dutch tax rulings met Dutch procedural requirements. Over 4,000 Dutch tax rulings were reviewed.
Current practice and review
A tax ruling provides Dutch taxpayers with the opportunity to obtain advance certainty on the tax consequences of proposed legal transactions. Taxpayers and the tax authorities are able to avoid potential disputes through tax rulings, which provide upfront assurance. The Dutch tax ruling practice is considered an important pillar of the Dutch business climate.Continue Reading
UK, US, Six Others Launch Multilateral Tax Risk Assurance Program For MNEs
The author is Alex Hunter, Editor, TP News. He oversees and updates the publication and also regularly writes news stories about transfer pricing and international tax law. Alex is reachable on email (editor@transferpricingnews.com) and by phone (+447808558597).
Eight tax administrations, including the UK and the US, have launched a pilot program for the multilateral risk assessment of multinational corporations.Continue Reading
Paulus Merks Joins Houthoff as Tax Partner
In a major expansion drive, Dutch law firm Houthoff has welcomed Paulus Merks as a new partner in the tax team.Continue Reading