WTS in Atlas Tax Lawyers

On 22 December 2021, the European Commission (“EC”) published a proposal for a directive to prevent the abuse of shell entities for improper tax purposes (hereafter: “ATAD3 Directive”).

Effective 1 January 2022, the Netherlands have implemented a ground-breaking legislation to end its long-standing practice of allowing unilateral downward TP adjustments.

The State Secretary’s Decree of 22 March 2019 (No. 2019-42405) describes the circumstances under which it may be assumed that the collective investment fund in question is under ‘special government supervision’.

Review of the EU proposal for a Council Directive amending the VAT Directive: a reduced VAT rate and place of supply rules for online events.

The Dutch Ministry of Finance kicked off an internet consultation on a draft proposal (the “Draft Bill”) to amend the Dutch codification of the arm’s-length principle. Group companies operating in the Netherlands are recommended to review their existing advance pricing agreements and/or tax rulings as well as their transfer pricing policies to assess the impact of this proposed amendment of the arm’s-length principle.

In the Netherlands, the Dutch Ministry of Finance has published a draft proposal under which downward adjustments would be limited in order to address transfer pricing mismatches when applying the arm’s-length principle.