Jean-Paul van den Berg and Johan Vrolijk of Stibbe describe certain corporate income tax matters included in a recent policy paper on the Dutch tax system that could affect cross-border transactions. They also analyse the legislative proposal regarding foreign currency results on exempt participations.
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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