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Landmark transfer pricing ruling favours leading Europe IT Distributor
In a recent landmark decision[1], the Danish Supreme Court ruled that EET Group A/S (the “taxpayer”) had acted in line with the arm’s length principle in relation to its controlled […]
State Secretary addresses key issues in revised FGR definition
IntroductionOn 12 June 2025, the Dutch State Secretary of Finance sent a letter to the House of Representatives addressing the key practical issues arising from the revised definition of the […]
Atlas Provada Drinks & Bites – 18 June 2025
We are delighted to invite you to the second edition of our exclusive networking event: Atlas Provada Drinks & Bites. In the garden of our office in the heart of […]
Key changes for foreign investors due to Dutch Fund Decree 2025
Effective 1 January 2025, the Netherlands has overhauled the tax-classification rules for foreign entities by introducing new laws and decrees. These revisions markedly affect both Dutch and foreign investment funds. […]
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 […]