AMCHAM Deloitte Transfer Pricing Seminar
Reporting Insight recently joined AMCHAM in the Netherlands, a non-profit, non-governmental, non-political, voluntary organization of companies and individuals who invest in and trade between the United States of America and the Netherlands. AMCHAM organizes several (networking) events and seminars for its members.
Dennis de Gier and Caroline Vogelsang attended the 21st annual Transfer Pricing Seminar at the Hilton Hotel in Amsterdam, hosted by Deloitte. We listened to an interesting presentation of the Head of Tax of Wessanen about their business and tax transparency. Afterwards, a Transfer Pricing partner of Deloitte US guided us through the Transfer Pricing considerations of US multinationals (outbound) presenting the following highlights:
• Reduction corporate tax rate from 35% to 21%
• Moves from worldwide business taxation to a partial participation exemption regime
• Limits business interest deductibility
• Net operating losses limited to 80% of taxable income with carryforward period (eliminated=s most carrybacks)
In addition, due to increasing transparency and anti-avoidance rules, the administrative burden is expected to increase significantly and tax accounting modeling will take place even on a monthly basis, resulting in more demand for Tax specialists and tax Accountants.
Parallel tot his session, Deloitte presented the Hamamatsu case, a recently given judgment by the European Court of Justice on Transfer Pricing and Customs. This case could have impact on the Advanced Pricing Agreements concluded by multinationals.