Loans

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…