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.
Geopolitical rivalry is reshaping global tax cooperation, as the OECD’s minimum tax framework fragments and the EU grapples with the ensuing legal fallout
Chile’s revamped GAAR marks a shift toward structural scrutiny, pushing MNEs to strengthen tax governance, economic substance and compliance strategies
While the IBS incorporates taxable events previously covered by state and municipal taxes, its governance and operational logic represent a significant departure from the legacy model