International community strikes a ground-breaking tax deal

Pillar One Pillar One, in general, offers a new taxing right for market jurisdictions focusing on the demand side (where customers are based) over a share of residual profit (Amount A) and a fixed return for (standardized) routine marketing and distribution activities (Amount B). It is expected that large online sales and technology companies making […]

Digital Services Tax Emerging in Africa

Under Action 1 of the BEPS Project, titled “Addressing the Tax Challenges of the Digital Economy”, the OECD has set out to establish a set of international standards to address BEPS in the digital economy. However, given that the work of the OECD/G20 Inclusive Framework is on-going, some countries have already undertaken unilateral tax measures […]

Existing benchmark studies are based on past data that do not capture new COVID-19 market conditions

The assumption that limited-risk companies should earn guaranteed returns might be questioned as a result of the COVID-19 outbreak. It is uncertain whether independent companies performing similar functions, assets and risks to limited-risk companies will report operating losses. Independent comparable companies may be compensated with different margins or even losses in 2020. Therefore, by relying […]

Dutch government shares its view on CJEU Danish cases

The questions mainly concern the interaction between the landmark CJEU judgements in six cases which deal with the application of the EC Parent-Subsidiary Directive and the EC Interest and Royalty Directive (see also our Blog on this subject) and the substance requirements according to Dutch legislative. The current substance requirements are (in short) that the […]

EU revises list of non-cooperative jurisdictions

Currently, 12 jurisdictions remain on the EU list of non-cooperative jurisdictions: American Samoa, Belize, Dominica, Fiji, Guam, Marshall Islands, Oman, Samoa, Trinidad and Tobago, United Arab Emirates, US Virgin Islands and Vanuatu. The Netherlands has significantly more jurisdictions placed on its blacklist. An overview of the jurisdictions (as well as their CIT tarif) of both […]

Russia challenges beneficial ownership Cypriot holding company

In order to answer this question the court had to consider the role of the Cypriot parent company and in particular whether it is perceived as the beneficial owner of the shares in the Russian company as well as the corresponding dividends. In determining the beneficial ownership of the Cypriot parent company the court set […]

Draft Decree on new ruling practice (the Netherlands)

Procedure According to the draft Decree the International Fiscal Certainty Team (the IFZ Team) will act as the first point of consultation for obtaining the majority of international tax rulings. This team will monitor and ensure unity in quality of/and adherence to the ruling practice and ruling policy. With respect to bilateral and multilateral APAs, […]

CJEU rules in Danish cases on beneficial ownership and treaty abuse

The joined cases (two dividend cases and four interest cases) revolve around Danish companies owned by a parent company in another EU Member State (Luxembourg, Cyprus and Sweden). Subsequently, these EU parent companies were all owned by companies resident outside the EU (such as Bermuda and the Cayman Islands) or by funds with investors in […]

Please feel free to exchange ideas with us on your tax position and/or that of your company.

Contactform

Locations

Nijmegen

FiftyTwoDegrees Jonkerbosplein 52 6534AB Nijmegen The Netherlands

Amsterdam

Nieuwezijds Voorburgwal 162 1012 SJ Amsterdam The Netherlands

Research and Articles

We collect cookies to analyze our website traffic and performance; we never collect any personal data. Read terms