The Resource Recent case law on captive insurance companies : what is the right transfer pricing approach?

Recent case law on captive insurance companies : what is the right transfer pricing approach?

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Recent case law on captive insurance companies : what is the right transfer pricing approach?
Title
Recent case law on captive insurance companies : what is the right transfer pricing approach?
Creator
Subject
Language
eng
Summary
A recent court case decided by the District Court in The Hague regarding a captive insurance company involved in reinsurance activities seems to follow the current general approach of the Dutch tax authorities on captives. This article considers this decision in light of existing Dutch case law and the UK Dixons case. There is a striking difference in the approaches taken by the District Court in The Hague and the UK Special Commissioners concerning the Dixons case. Where the decision in the Dixons case focuses on the appropriateness of the transfer pricing method, the District Court in The Hague reclassifies the transactions under review. This article discusses these different approaches to captives, in particular in the context of the OECD Guidelines
Citation source
In: International transfer pricing journal. - Amsterdam. - Vol. 19 (2012),
http://library.link/vocab/creatorName
  • Reyneveld, J
  • Bonekamp, M
Geographic coverage
  • European Union
  • Europe
Language note
English
http://library.link/vocab/subjectName
  • OECD Transfer Pricing Guidelines
  • case law
  • captive insurance company
  • transfer pricing
Label
Recent case law on captive insurance companies : what is the right transfer pricing approach?
Instantiates
Publication
Label
Recent case law on captive insurance companies : what is the right transfer pricing approach?
Publication

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      Rietlandpark 301, Amsterdam, 1019 DW, NL
      52.37366609999999 4.9336932
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