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.
While the manual should be consulted for any questions around MAPs, the OECD’s Sriram Govind also emphasised that the guidance is ‘not a political commitment’
The landmark Indian Supreme Court judgment redefines GAAR, JAAR and treaty safeguards, rejects protections for indirect transfers and tightens conditions for Mauritius‑based investors claiming DTAA relief
As tax teams face pressure from complex rules and manual processes, adopting clear ownership, clean data and adaptable technology is essential, writes Russell Gammon, chief innovation officer at Tax Systems