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Dutch Transfer Pricing Court Case on Business Restructuring:Preventing Transfer Pricing Disputes by Getting Certainty in Advance
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作者 Jin Chen 《Belt and Road Initiative Tax Journal》 2023年第2期94-97,共4页
This article summarizes a Dutch court case regarding a business restructuring within a multinational enterprise,where the valuation of the transferred business activities was not confirmed by the tax authorities in ad... This article summarizes a Dutch court case regarding a business restructuring within a multinational enterprise,where the valuation of the transferred business activities was not confirmed by the tax authorities in advance.As a result of the lack of certainty beforehand,the taxpayer experienced a significant tax correction.According to the author’s perspective,this situation could have been prevented by seeking certainty in advance. 展开更多
关键词 Dispute resolution Transfer pricing Advance pricing agreement Tax certainty Business restructuring
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