Arm’s Length

Arm's Length, CJEU, Loans

(Assistant Professor at the University of Amsterdam /Senior Manager Tax at PwC Netherlands Tax Knowledge Centre.) and (Associate at Maisto e Associati, Italy)/ /Leave a comment

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 palindrome is a word, phrase, or sentence that reads the same backward as forward. The term “palindrome” originates from the Greek words “palin” (meaning “again”) and “drome”…

Arm's Length, Loans, Transfer Pricing

(Loyens & Loeff, Netherlands)/ /Leave a comment

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 parties, which is concluded on arm’s length terms, be abusive? Does compliance with the arm’s length requirement provide “a transfer pricing…

Arm's Length, ESG, International Tax Law, Transfer Pricing

(University of Hamburg; Tax administration, Germany), (University of Applied Sciences Düsseldorf), and (Quantum Transfer Pricing)/ /Leave a comment

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 generations. Various reports and goals were agreed upon internationally (e.g. Brundtland Report and Sustainable Development Goals)….

Arm's Length, Beneficial ownership, Carbon neutrality, CJEU, Digital platforms, EC Tax Review, EU VAT, VAT

(General Editor EC Tax Review and tax adviser at Ernst & Young Belastingadviseurs LLP)/ /Leave a comment

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 Bumpy Since the Conference of the Parties (COP) in Glasgow in November 2021 (COP26) the world has changed dramatically. In February…

Arm's Length, DEBRA, Deduction, Digital services tax, Intertax, Pillar II, Tax Theory, Unitary Taxation

(General Editor of Intertax)/ /Leave a comment

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 & Caren Sureth-Sloane, Towards an Amended Arm’s Length Principle: Tackling Complexity and Implementing Destination Rules in Transfer Pricing The arm’s length principle (ALP) is the…

Arm's Length, CJEU, EFTA

(Erasmus School of Law, Erasmus University Rotterdam, PwC Rotterdam) and (affiliated with the University of Amsterdam (UoA), Amsterdam, the Netherlands, and EY, Rotterdam, the Netherlands)/ /Leave a comment

 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 scope of the EEA Treaty freedoms by reference to the arm’s-length standard. The EFTA Court does so in the same…