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Transfer pricing and Customs valuation: first European ruling on TP adjustments
The Court of Justice of the European Union (CJEU) recently ruled, for the first time, on the impact of transfer pricing (TP) retrospective adjustments on the customs value of the goods, in the Case C-529/16 Hamamatsu Photonics Deutschland GmbH. Th...
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Rulings subject of tax discussion: justified or not?
In the Netherlands, tax rulings have been subject to discussion for some time now. The financial media are in favour of abolishing these so-called tax deals, as they feel they do more harm than good. In their opinion, abolishing these rulings woul...
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OECD BEPS Action 1: Taxation of Digital Economy – New VAT practices in Turkey
Article 9 of the Turkish Value Added Tax (VAT) Law on the “Party Liable for Tax” was amended on 28 November 2017. The amended article applies as of 1 January 2018. The amendment stipulates that VAT arising from services provided electronically by ...
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New Tax Legislation Consequences on U.S. Transfer Pricing and Intangibles
The Tax Cuts and Jobs Act of 2017 (the Act) brought sweeping changes to the international tax landscape, including the transfer pricing arena. Intangible property is at the core of many of these changes. The impact of the new provisions generally ...
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£107 million Diverted Profit Tax charge to Diageo: Is it a tax?! Is it a penalty?! Or is it proof that HMRC has superpowers…
On May 10, Diageo, a FTSE 100 alcoholic beverage company, reported that it will have to pay a Diverted Profit Tax charge of £107 million in relation to a period of just 15 months. This evidences the approach HMRC is taking in inquiries where it do...
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