The Resource Determining arm's length remuneration for Dutch royalty licensing companies

Determining arm's length remuneration for Dutch royalty licensing companies

Label
Determining arm's length remuneration for Dutch royalty licensing companies
Title
Determining arm's length remuneration for Dutch royalty licensing companies
Creator
Subject
Language
eng
Summary
Following a period of uncertainty, it is again possible to obtain a favourable tax ruling (APA) for Dutch companies involved in licensing activities. In order to gain such a ruling, the Dutch tax authorities require that Dutch royalty licensing companies have economic substance, put a certain amount of equity at risk and earn an arm's length remuneration commensurate with their functions and risks. This article considers the requirements of the Dutch tax authorities in relation to the remuneration of royalty licensing companies and also describes the economic analysis required to implement the requirements of the Dutch tax authorities. The article is based on experience in agreeing a recent APA with the Dutch authorities
Citation source
In: Tax planning international : European Union focus. - London. - Vol. 8 (2006),
http://library.link/vocab/creatorName
  • Boer, D. de
  • Boyle, A
Geographic coverage
  • European Union
  • Europe
Language note
English
http://library.link/vocab/subjectName
  • APA
  • arm's length principle
  • royalties
  • licensing company
  • remuneration
Label
Determining arm's length remuneration for Dutch royalty licensing companies
Instantiates
Publication
Label
Determining arm's length remuneration for Dutch royalty licensing companies
Publication

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