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    The OECD BAPA Manual: focus on international alignment

    On September 13th 2022 the OECD Forum on Tax Administration’s Bilateral Advance Pricing Arrangement Manual (“the BAPA Manual”) was approved by the OECD Committee on Fiscal Affairs. The manual covers almost 100 pages and addresses many issues that ...
    On September 13th 2022 the OECD Forum on Tax Administration’s Bilateral Advance Pricing Arrangement Manual (“the BAPA Manual”) ...
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    What’s new? – New Decree on Profit Allocation for Permanent Establishments

    The Netherlands recently published its new guidance on allocation of profits to a Permanent Establishment (“PE”). The existing guidelines for such profit allocation already showed that, next to the discussion on the existence of a PE the profit al...
    The Netherlands recently published its new guidance on allocation of profits to a Permanent Establishment (“PE”). The existing ...
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    The four key trends from the Dutch Transfer Pricing decree that will impact business

    On 1 July 2022, the Dutch State Secretary for Finance issued a new Transfer Pricing Decree (hereafter: “the Decree”). For those unfamiliar with the Decree: legislation in the Netherlands on Transfer Pricing is relatively limited and the OECD Trans...
    On 1 July 2022, the Dutch State Secretary for Finance issued a new Transfer Pricing Decree (hereafter: “the Decree”). For those...
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    Aligning your transfer pricing policy with Pillar Two –preparations and forecasts for 2022

    In our November 2021 blog on Pillar Two, we informed you about the key elements of Pillar Two, including the most important transfer pricing elements. In this blog, we share our view on how you can best prepare now that the introduction in FY 2024...
    In our November 2021 blog on Pillar Two, we informed you about the key elements of Pillar Two, including the most important tra...
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    How to prepare for transfer pricing?

    Transfer pricing can seem like a daunting process, but with some outside help things can get a whole lot easier. Our tip? Book a transfer pricing brainstorming session with our experts! Having the necessary transfer pricing documentation in place ...
    Transfer pricing can seem like a daunting process, but with some outside help things can get a whole lot easier. Our tip? Book ...
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    The benefits of a strategic session

    Would you like to learn more about the importance of transfer pricing for your company? A strategic (or brainstorming) session is the perfect way to get acquainted with various transfer pricing topics and to address issues related to transfer pric...
    Would you like to learn more about the importance of transfer pricing for your company? A strategic (or brainstorming) session ...
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    Case study: How to turn an aggressive audit into an opportunity

    As Albert Einstein once said, “in the midst of every crisis, lies great opportunity”. Most CFOs and tax directors see a tax audit only as a big risk that eats up capacity, causes stress and creates uncertainty. However, tax audits often also have ...
    As Albert Einstein once said, “in the midst of every crisis, lies great opportunity”. Most CFOs and tax directors see a tax aud...
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    Dutch legislation on the elimination of mismatches in the application of the arm’s length principle

    On 1 January 2022, the Dutch legislation on the elimination of mismatches in the application of the arm’s length principle (“Wet tegengaan mismatches bij toepassing zakelijkheidsbeginsel”) entered into force. This legislation aims to eliminate dou...
    On 1 January 2022, the Dutch legislation on the elimination of mismatches in the application of the arm’s length principle (“We...
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