IBOR transition, reconsideration of intercompany financing transactions is required
Because of the financial crisis and the LIBOR scandal, a global project to reform interest benchmark rates has started in 2013. Several existing interbank offered rates (IBORs) such as the Euribor and LIBOR are in the process of being renewed or p...
Because of the financial crisis and the LIBOR scandal, a global project to reform interest benchmark rates has started in 2013....
Read moreDevelopments in intercompany financial transactions
The transfer pricing aspects of intercompany financial transactions are often considered to be complicated. These difficulties arise due to the characteristics of financial instruments and continuous developments of financial markets. In this blog...
The transfer pricing aspects of intercompany financial transactions are often considered to be complicated. These difficulties ...
Read moreTransfer Pricing & Mandatory Disclosure
The EU Mandatory Disclosure Directive (MDD/DAC6) obliges intermediaries and taxpayers to report certain tax and TP arrangements to tax authorities. This will increase the compliance burden for companies and tax intermediaries. Certain TP arrangeme...
The EU Mandatory Disclosure Directive (MDD/DAC6) obliges intermediaries and taxpayers to report certain tax and TP arrangements...
Read moreOECD pillar one and two blueprints
In October and November 2019, the OECD released discussion drafts as part of BEPS Action 1 on taxation in the digital economy. The proposals of the OECD consisted of two main “pillars”. Initially, the OECD intended to release final reports in Octo...
In October and November 2019, the OECD released discussion drafts as part of BEPS Action 1 on taxation in the digital economy. ...
Read moreTransfer pricing documentation update: now is the right moment to act!
Most countries require companies to prepare transfer pricing documentation on a yearly basis. This relates for example to the master file, local files, and other local transfer pricing forms. It is important to meet these yearly documentation requ...
Most countries require companies to prepare transfer pricing documentation on a yearly basis. This relates for example to the m...
Read moreDebate on BEPS, Transfer Pricing, EU State Aid and the developments in the Netherlands
Theo Elshof took part in the discussion on EU state aid, the future of transfer pricing and the policies with prominent Dutch tax specialists such as Marlies de Ruiter, former lead of the BEPS project of the OECD, Harry Roodbeen director of Minist...
Theo Elshof took part in the discussion on EU state aid, the future of transfer pricing and the policies with prominent Dutch t...
Read moreTP risk management in the post-COVID-19 era
The COVID-19 pandemic has hit almost every country in the world. As the COVID-19 crisis has major economic consequences for most countries, governments are facing huge costs to finance economic stimulus packages of an unprecedented volume. To make...
The COVID-19 pandemic has hit almost every country in the world. As the COVID-19 crisis has major economic consequences for mos...
Read moreCooperative Compliance 2.0
1.1 Introduction In 2018 the OECD has introduced a new strategy to improve co-operative compliance amongst its member states. It was based on the OECD Project ‘International Compliance Assurance Programme’ (ICAP). The key principles addressed are:...
1.1 Introduction In 2018 the OECD has introduced a new strategy to improve co-operative compliance amongst its member states. I...
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