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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.
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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.

Key highlights from the Tax Plan 2024

On Tuesday, September 19, 2023 (Budget Day), the outgoing Dutch Minister of Finance revealed the Tax Plan 2024 in which several tax measures were announced. You will find our publication Tax Plan 2024 Special attached, in which we outlined the most important measures from an international perspective. Please note that the proposals are subject to discussion and approval by the Dutch Parliament.

European Commission Introduces new rules to prevent the misuse of shell entities

On 22 December 2021, the European Commission proposed new rules aimed against the misuse of shell entities for improper tax purposes. Based on the proposal, EU companies that qualify as shell entities may be disallowed to claim tax advantages under an applicable tax treaty or EU directive.