News
Transfer Pricing in Brazil: Practical Aspects in the Adaptation of the Arm’s Length Standard
Brazilian taxpayers need to comply with new OECD-based transfer pricing rules as of financial years starting on or after 1 January 2024. They are also allowed to apply the new…
Webinar: Pillar Two - Deep Dive OECD Safe Harbours
When: February 8, 2023 Time: 4 - 5 pm On December 15, 2022, the EU directive on global minimum taxation (GloBE Rules or Pillar Two) was passed. The OECD subsequently…
Atlas welcomes Taco to the partner team and Yvonne to the counsel team
We are delighted to announce that Atlas Tax Lawyers has appointed Taco Wiertsema as Partner and Yvonne Bakker as Counsel, as of January 1st, 2023. Taco is a member of…
CJEU annuls the EC’s Fiat-Chrysler state aid ruling
On 8 November 2022, the Court of Justice of the European Union (CJEU) issued a long-awaited (landmark) decision in the Fiat-Chrysler state aid case. The CJEU set aside the judgement…
Publications
The ATAD general anti-avoidance rule in the Netherlands
The Dutch legislator decided not to implement the General Anti-Avoidance Rule (“GAAR”) of the EU Anti-Tax Avoidance Directive (“ATAD”) and to rely on the court developed fraus legis doctrine. As there are several…
Economic Analysis and Impact Assessment of the Pillar 1 & 2 Proposals
On 13 February 2020, the OECD published a (first) economic analysis / impact assessment of the (combined) Pillar 1 & 2 proposals). Background The OECD recently published the proposals for…
OECD releases Transfer Pricing Guidance on Financial Transactions
On February 11, 2020 the OECD released the highly anticipated report “Transfer Pricing Guidance on Financial Transactions” (“the report”), which deals with the follow-up work in relation to Actions 8-10…
Abuse of Law under EU Directives - Derivatives & Financial Instruments, 2019 (Volume 21), No. 6
In this article the authors Frederik Mulder and Yves Cattel discuss the ruling of the European Court of Justice in the so-called “Danish cases” (T Danmark – Case C-116/16 and…
