Search results with tag "Safe harbour"
Statement on a Two-Pillar Solution to Address the Tax ...
www.oecd.orgMarketing and distribution profits safe harbour Where the residual profits of an in-scope MNE are already taxed in a market jurisdiction, a marketing and distribution profits safe harbour will cap the residual profits allocated to the market jurisdiction through Amount A. Further work on the design of the safe harbour will be undertaken ...
Transfer Pricing Country Profile- Netherlands - OECD
www.oecd.orgSafe Harbours and Other Simplification Measures 26 Does your jurisdiction have rules on safe harbours in respect of certain industries, types of taxpayers, or types of transactions? ☒Yes ☐ No The Netherlands has incorporated the OECD’s low value adding services approach which could be considered as a safe harbour (see question 16).
Court of Justice of the European Union PRESS RELEASE No …
curia.europa.eualia, that, in Decision 2000/5205 (‘the Safe Harbour Decision’), the Commission had found that the United States ensured an adequate level of protection. In a judgment delivered on 6 October 2015, the Court of Justice, before which the High Court (Ireland) had referred questions for …
Navigate your way to a Safe Harbour - TMA
www.turnaround.org.au6 TMA BEST PRACTICE GUIDELINES TMA BEST PRACTICE GUIDELINES 7 ASSESSMENT OF SOLVENCY The directors must undertake an initial assessment of whether the company is ...