The third and final article on the use of credit ratings by transfer pricing practitioners and tax authorities, in the mini-series by Joris Steunenberg and Mick Willemsen, has been published on Transfer Pricing Week (“TP Week”). The third article provides…
The second article on the use of credit ratings by transfer pricing practitioners and tax authorities, in the mini-series by Joris Steunenberg and Mick Willemsen, has been published on Transfer Pricing Week (“TP Week”). The second article provides a framework…
Atlas is very proud to be recognized by the market as Tier 2 in the 2019 Tax Advisory Survey of the International Tax Review. The survey is carried out among ITR’s global readers including global tax directors, who were asked…
Joris Steunenberg and Mick Willemsen have written three technical articles on the use of credit ratings by transfer pricing practitioners and tax authorities, which are published on TP Week in the coming weeks as a mini-series. The technical articles concern…
On 2 July 2019, the legislative proposal to implement the provisions of the EU Anti-Tax Avoidance Directive 2 (ATAD2) was submitted to the Dutch parliament. ATAD 2 combats both hybrid mismatches among EU Member States and between EU Member States…
On 28 June 2019, the State secretary of Finance published a decree on the revised ruling policy for rulings with an international character (hereinafter: international rulings). This decree replaces three previous decrees on the ruling policy (dated 3 June 2014)…
Recent heeft het Hof Van Justitie van de EU geoordeeld dat een commissaris, ondanks dat de toezichthoudende activiteiten gezien kan worden als een economische activiteit, geen btw ondernemer is. Dit oordeel heeft in veel gevallen een impact op de btw…
On 26 February 2019, the Court of Justice of the European Union (CJEU) took a decision in the so-called “Beneficial Ownership Cases”, concerning the application of the Interest and Royalty Directive (IRD) and the Parent-/Subsidiary Directive (PSD). In the decisions, the CJEU ruled that Member States must deny the benefits granted under the two Directives in case of an abusive situation. In response of this CJEU ruling, members of the Dutch parliament raised several questions to the Ministry of Finance on the interpretation of the rulings and the Dutch reading of ‘abusive structures’. In a letter of 14 June 2019, the Dutch State Secretary of Finance addressed the questions.
On 31 May 2019, the Organisation for Economic Co-operation and Development (OECD) released a Workplan (“Programme of Work to Develop a Consensus Solution to the Tax Challenges Arising from the Digitalisation of the Economy”) setting out a process to reach a new global agreement on future taxation of multinational enterprises. The workplan aims to resolve the tax challenges arising from the global digitalisation of economies and explores technical issues to be resolved through two main pillars (see our newsalert here on the two main pillars).
We are happy to welcome Luis Rosas from Mexico to our office for a three months secondment. He is working for Turanzas, Bravo & Ambrosi, the WTS member firm in Mexico. Luis has a lot of experience advising his Mexican…
In December 2018 the Dutch State Secretary of Finance announced that he would introduce a new policy for obtaining tax rulings with an international character. On 23 April 2019 a new (draft) Decree for international tax rulings was published. In…
Three members of the Dutch House of Representatives jointly prepared a legislative proposal that should limit the current liquidation loss scheme (applicable to participations) and the related cessation loss scheme (applicable to permanent establishments) on 16 April 2019. The legislative proposal and the Explanatory Memorandum were published as an internet consultation to give interested parties the opportunity to respond to the draft legislative proposal.
Currently the liquidation loss scheme and the related cessation loss scheme enable Dutch taxpayers to offset their liquidation losses related to worldwide subsidiaries and permanent establishments at the moment these losses would otherwise be permanently lost. The legislative proposal suggests to include a material, territorial and temporal limitation to these schemes.
