The tax authorities have lost a transfer pricing case in the Dutch Supreme Court. Following the new codification of the arm’s-length principle, however, taxpayers may not always be so lucky – insufficient transfer documentation can reverse the burden of proof. By Dave Rutges, Eduard Sporken and Barry Larking, KPMG Meijburg & Co, Amstelveen, the Netherlands
Unlock this content.
The content you are trying to view is exclusive to our subscribers.
Tax advisers should revisit India secondment arrangements after the EY US ruling strengthened the Centrica precedent and raised fresh withholding concerns
After joining Milbank from Akin Gump, the fund tax specialist discusses sponsor demand, practice building, and the tax challenges facing asset managers
New research, which suggests LLMs can silently corrupt complex documents, should alert tax and legal teams relying on AI to handle iterative drafting and compliance workflows