More multinationals will switch their operational structure from a commissionaire to a limited risk distributor (LRD) in response to the OECD base erosion and profit shifting (BEPS) initiative, advisers expect. This would make calculating VAT less complex from an accounting perspective.
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The Court of Appeal ruling clarifies that treaty benefits are not abusive where transactions are commercially driven, providing greater certainty on “main purpose” anti-avoidance tests
Despite the Netherlands featuring an unusual concentration of World Tax-ranked technology-led providers, sources believe there’s a long way to go to challenge the established players
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