Arm's Length

Transfer pricing adjustments under Article 9 of the model treaties are the most common form of dispute that is dealt with under the mutual agreement procedure. It is for this reason that the OECD…

"When I use a word," Humpty Dumpty said in rather a scornful tone, " it means just what I choose it to mean, neither more nor less." (Lewis Carroll, Alice through the Looking Glass) Prior to the OECD…

Vassilis Dafnomilis (Assistant Professor at the University of Amsterdam / Senior Manager Tax at PwC Netherlands Tax Knowledge Centre) Francesco Semonella (Associate at Maisto e Associati, Italy)[1] A…

The opinion of AG Emiliou in X BV v. the Dutch Ministry of Finance (C-585/22) Dr. Svitlana Buriak (Loyens & Loeff / University of Amsterdam)[1]   Can a transaction entered into between two associated…

Climate change and the use of natural resources present us all with a major challenge. We all have our part in it and we can all contribute to ensure that we do not live at the expense of future…

We are happy to inform you that the latest issue of the journal is now available and includes the following contributions: Han Kogels, A Changing World Making the Road to Carbon Neutrality Even More…

We are happy to inform you that the latest issue of the journal is now available and includes the following contributions:   Stefan Greil, Michael Overesch, Anna Rohlfing-Bastian, Ulrich Schreiber &…

 Summary The Court of the European Free Trade Association – the EFTA equivalent of the CJEU – now also is demarcating the room for manoeuvre for the Member States in company tax matters within the…