Jian-Cheng Ku, Tim Mulder, and Rhys Bane of DLA Piper, Amsterdam, discuss the CJEU Advocate General’s opinion, delivered October 25, concluding that, following the Groupe Steria decision, aspects of the Dutch tax consolidation regime violate EU concepts of freedom of establishment and are thus contrary to EU law . . .
The OECD has today published peer review reports that critique the tax treaty dispute resolution process of six countries: United States, Belgium, Canada, the Netherlands, Switzerland, and the United Kingdom. The peer review was conducted by the “Inclusive Framework on BEPS,” comprised of over 100 countries that have pledged to . . .
The United States has so far put in place 11 bilateral competent authority arrangements for the automatic exchange of country-by-country reports, the OECD reported a June 22 release. The US now has . . .
Eight countries are working on a new program to jointly review large multinationals’ tax affairs and, if appropriate, provide assurances to the multinational that it will not likely be audited in those jurisdictions with respect to specific tax risks, officials said June 6 in Washington at a conference sponsored by the OECD, USCIB, . . .
The Dutch Supreme Court has asked the Court of Justice of the European Union to resolve two separate disputes concerning whether the Netherlands can deny foreign investment funds refunds of the Dutch dividend withholding . . .