1. Home
  2. Knowledge

Our knowledge We would like to share our knowledge with you.

Dirkzwager actively shares knowledge with everyone who requires legal or tax-related information. Why? In order to improve our services and to extend our network. Sharing knowledge is power. It provides a client with understanding and makes collaboration and the provision of advice more targeted. Sharing knowledge constitutes the basis of all that we do.
4 filter(s) active

Practice area

Select the desired filter items

  • Not possible filters

Sector

Select the desired filter items

  • Selected filters
  • Possible filters
  • Not possible filters

Theme

Select the desired filter items

  • Selected filters
  • Possible filters
  • Not possible filters

Author

Select the desired filter items

  • Selected filters
  • Not possible filters
Zoekopdracht delen:
Number of search results: 5

Revamping Transfer Pricing

On 12 September 2023, the European Commission introduced two directive proposals. One of the proposals, relates to transfer pricing (“TP Directive”) and aims to reshape the landscape of transfer pricing (“TP”) regulations across the single market. If unanimously accepted by all EU Member States, these rules would result in (more or less) harmonized TP rules. Member States would be obligated to apply the at arm’s length principle in line with the OECD TP Guidelines and taxpayers would be required to apply the most appropriate TP method. Furthermore, the TP Directive offers methods to avoid double taxation and a fast-track procedure to resolve double taxation. These rules would apply as from 1 January 2026.

European corporate income tax base – BEFIT

On 12 September 2023, the European Commission introduced two directive proposals. One of the proposals (“BEFIT”) aims to improve efficiency for both corporate income taxpayers and tax authorities by introducing a new, single set of rules to determine the tax base of (European) groups of companies. This proposal replaces the previous proposals regarding a harmonized European corporate income tax base (CCTB and CCCTB). If unanimously accepted by all EU member states, these rules would apply as from 1 July 2028.

No longer lengthy, costly and cumbersome withholding tax procedures?

In the current environment, EU Member States often levy withholding tax on dividends and interest paid. Subsequently, this withholding tax paid may be eligible for a refund based on tax treaties. The procedures for such refunds can be problematic in practice and differ significantly per Member State. The European Commission has now proposed new rules in order to streamline and simplify withholding tax procedures in the EU. In addition, these rules aim to prohibit the abuse of refund procedures. The current proposal only applies to publicly traded shares and, where applicable, interest from publicly traded bond.

Dutch legislative proposal on Pillar 2 implementation submitted with Parliament

In our blog of 23 December 2023, we discussed the draft legislative proposal Minimum Tax Law 2024 (“Wet minimumbelasting 2024”). We hereby inform you that the legislative proposal is no longer in draft and has been sent to the Dutch House of Representatives on 31 May 2023. Once accepted, it will be reviewed in the Dutch Senate before entering into force.

Draft Minimum Tax law 2024

On Monday 12 December 2022 the EU Member States reached an agreement about the EU wide implementation of the rules aimed at introducing a global minimum tax of 15% on profits of multinational enterprises. The Committee of Permanent Representatives approved the draft EU Directive prepared for this purpose and submitted it with the Council to be formally adopted in a further written procedure. The Directive provides for the European implementation of the initiative agreed on by the OECD/G20 Inclusive Framework on Base Erosion and Profit Shifting in October 2021 as part of its “Two Pillar Solution to Address the Tax Challenges Arising From the Digitalisation of the Economy”. Member States are required to implement the Directive into their national law by 31 December 2023 at the latest. The Netherlands was anticipating this and had already shared a draft Bill introducing an entirely new law, the Minimum Tax Law 2024 (“Wet minimumbelasting 2024”) for input from the general public in an online consultation. This blog summarizes key aspects of the Dutch implementation proposal and how multinationals should prepare.