Supplementary Decree Allocation of Profits to Permanent Establishments recommended

Research output: Contribution to journalArticleProfessional

Abstract

Other than the Dutch Transfer Pricing Decrees 2001 and 2004 the Transfer Pricing Decree issued on14 November 2013 no. IFZ 2013/184 M refers only to transfer pricing issues of associated companies. It does not contain any tax policy clarifications regarding the allocation of profits to permanent establishments. The Secretary of State for Finance did not consider such information necessary as guidance on the allocation of profits to permanent establishments is provided in his Decree of 15 January 2011, IFZ 2010/457M. For several reasons a supplementary PE-Decree is recommended.
Translated title of the contributionSupplementary Decree Allocation of Profits to Permanent Establishments recommended
Original languageDutch
Pages (from-to)1-3
Number of pages3
JournalNederlands Tijdschrift voor Fiscaal Recht
Volume15
Issue number2014/2511
Publication statusPublished - 23-Oct-2014

Keywords

  • tax
  • profit allocation

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