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Implementation renewed Dutch ruling practice

As per 1 July 2019, a new Decree on international tax rulings [1] (including Advance Pricing Agreements and Advance Tax Rulings), entered into force. The Decree of 19 June 2019 replaces the previous Decrees of 3 June 2014. However, rulings signed ...
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Quantera Global strengthens strategic position in Poland

Quantera Global, one of the world’s leading independent transfer pricing advisory firms, is proud to announce its strategic partnership with Enodo Advisors, a Polish professional services firm specialising in transfer pricing and tax advisory. Thi...
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Proposed new policy Dutch ruling practice – What’s new?

On 23 April 2019, the new proposed Decree on international tax rulings (including Advance Pricing Agreements and Advance Tax Rulings) was published by the Dutch Secretary of State for Finance. It is intended that the new Decree will be implemented...
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UK tax authority indicates intensified focus on transfer pricing by launching a Profit Diversion Compliance Facility

After the introduction of the Diverted profit tax (“DPT”), on 10 January 2019 HM Revenue & Customs (“HMRC”) launched a new profit disclosure facility, Profit Diversion Compliance Facility (“PDCF”). The PDCF is designed for multinational enterp...
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Arm’s length principle encounters the big fluffy hairy finance animal

Introduction With the recently published discussion draft of the OECD on Financial Transactions of 3th July 2018 a new chapter is added to the question whether the at arm’s length principle (“ALP”) applied for transfer pricing purposes will be str...
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