Dutch Supreme Court case ruling on information provision

Resource Information

The work Dutch Supreme Court case ruling on information provision represents a distinct intellectual or artistic creation found in International Bureau of Fiscal Documentation. This resource is a combination of several types including: Work, Language Material, Continuing Resources.

Label

Dutch Supreme Court case ruling on information provision

Creator

• Brandt, R
• Jie-A-Joen, C

Subject

• due diligence
• information return
• burden of proof
• transfer pricing
• patent
• case law

Language

eng

Summary

This article examines a case from the Dutch Supreme Court, in which was decided that the burden of proof reversed to the taxpayer, because it refused to provide meeting notes of management and commissioner meetings to the tax inspector. The taxpayer also refused to hand over a due diligence report to the tax inspector. In this respect the Supreme Court decided that the 'fair play' principle restricts the tax inspector in its authority to ask for reports or information of third parties that has the goal to discuss the tax position of the taxplayer or to provide tax advise to taxpayer. A transfer pricing dispute also arose regarding the ownership of (patent) rights on several products

Citation source

In: Tax planning international transfer pricing. - London. - Vol. 7 (2006),

Geographic coverage

International

Language note

English