The Resource Business restructuring and permanent establishments : Netherlands

Business restructuring and permanent establishments : Netherlands

Label
Business restructuring and permanent establishments : Netherlands
Title
Business restructuring and permanent establishments : Netherlands
Creator
Subject
Language
eng
Summary
Part of a comparative survey examining the commonly implemented supply chain management structures. The OECD's Centre for Tax Policy and Administration (CTPA) discussed the potential tax aspects of business restructuring during its second CTPA Roundtable. In addition to the economic and commercial background of business restructuring, the tax aspects surrounding such transactions, including the transfer pricing aspects and permanent establishment (PE) issues, were addressed. One of the key questions of the CTPA Roundtable pertained to the notion of a deemed PE created by activities of a limited function for the foreign related party for which a local entity is acting. It is expected that the current OECD draft guidance pertaining to profit attributions to PEs will be finalized in 2007 and as such included in the commentary to the OECD Model Treaty and the OECD Transfer Pricing Guidelines. Furthermore, the OECD Working Party No. 1 and No. 6 are considering to broaden the PE concept and to lower the PE threshold for tax-driven restructuring. This article discusses the Dutch aspects of such PE issues and illustrates how this issue is intertwined with the transfer pricing model under a centralized, limited-risk business model
Citation source
In: International transfer pricing journal. - Amsterdam. - Vol. 13 (2006),
http://library.link/vocab/creatorName
  • Kuppens, J
  • Oosterhoff, D
Geographic coverage
  • European Union
  • Europe
Language note
English
http://library.link/vocab/subjectName
  • transfer pricing
  • PE
  • contract manufacturing
Label
Business restructuring and permanent establishments : Netherlands
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Publication
Label
Business restructuring and permanent establishments : Netherlands
Publication

Library Locations

    • IBFD Library AmsterdamBorrow it
      Rietlandpark 301, Amsterdam, 1019 DW, NL
      52.3736660 4.9336932
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