The COVID-19 pandemic has created significant uncertainty forbusinesses worldwide and the real impact on companies is stillemerging. Many companies are facing the spectre of losses andare looking for enhanced liquidity,…

Het corona virus heeft niet alleen een enorme persoonlijk impact, maar heeft ook een enorme impact op de economie en op ondernemers. In onze nieuwsbrief besteden we specifiek aandacht aan…

The COVID-19 pandemic has forced governments to take unprecedented measures such as restricting travel and implementing strict quarantine requirements. As a result of these measures, many cross-border workers are unable…

Recent case law across Europe shows that domestic courts are being inspired by the CJEU case law on abuse. In this newsletter we have summarised recent case law in Switzerland,…

At the beginning of this week, on 5 October, the Dutch Ministry of Finance submitted a proposal to parliament regarding changes to the loss compensation rules for Dutch corporate taxpayers.…

In the scope of the 2021 Tax Plan, the Dutch Ministry of Finance announced its intention to introduce a bill of law which will limit unilateral downward transfer pricing adjustments…

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…

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…

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…