MDDP Insight

MDDP Insight

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Corporate tax
Transfer pricing
VAT
Transfer pricing adjustments under the magnifying glass of tax authorities - trends in 2023
Price adjustments are still not a clear-cut issue and raise questions for taxpayers. In 2023, administrative...
The importance of benchmarking quality in financial transactions
Intra-group loan Intra-group loans, like other related party transactions, should be made on an arm’s...
Business development and the potential of tools for transfer pricing planning
In the dynamic business world, planning of settlement between related parties is becoming an essential...
APA-C as a report on the implementation of the APA agreement
An APA (advance pricing arrangement) is an agreement on the transfer price applied in transactions between...
Keep transfer pricing in mind when planning ESG
Recently, there has been a noticeable increase in interest in ESG topics. This is due to two reasons:...
The deadline for CBC-P filing is approaching
The deadline for submitting the CBC notification (CBC-P) for 2023 to the Head of KAS is coming soon –...
Why is it important to accurately determinate the functional profile?
Why is it important to accurately determine the functional profile? The functional profile should be...
Benefit test under the magnifying glass of tax authorities and KAS
Recently, intangible services have been one of the key areas reviewed during tax audits. As statistics...
Establishment a permanent establishment and transfer pricing obligations
Establishment a permanent establishment and transfer pricing obligations Conducting business in another...
Are you submitting a TPR? - Don't forget about complimentary services
Are you submitting a TPR? – Don’t forget about complimentary services There are only 3 days...
Last call: Significant changes to take info account before submitting TPR
When planning to submit transfer pricing information (hereinafter: TPR) for the tax year beginning after...
Impact of classification of goods on customs duties - opinion of the Advocate General of the CJEU in case C-104/23
On January 18, 2024, the Advocate General of the Court of Justice of the European Union issued an opinion...
Who submits the TPR form after a merger?
The dynamically changing economic situation, continuous development of competition in most industries...
Planning, rather than mere compliance, is the essence of transfer pricing
For most taxpayers, transfer pricing is associated with numerous and complex formal requirements that...
Use of OECD guidelines in EU jurisprudence
At the end of last year, the outcome of the Amazon group’s tax dispute was widely reported in the...
SUP fee - ecology yes, but with VAT?
This year, when selling food or beverages in single-use packaging to consumers, a SUP fee they must be...
Changes in the base interest rate and margins – announcement regarding transfer pricing!
The new Notice of the Minister of Finance on the announcement of the type of base interest rate and margin...
Are transactions between spouses subject to transfer pricing obligations?
On July 3, 2023, a parliamentary interpellation was submitted to the Minister of Finance regarding the...
TP adjustments - to show or not to show in VAT settlements?
Many companies in capital groups make an annual price adjustment in transactions with a related company...
Can hard-to-value intangibles actually be problematic?
We recently wrote on our blog about intangible assets and accounting for them. In this post, we would...
Factors affecting the tariff classification of goods
The Court of Justice of the European Union (CJEU) confirmed in its judgment of 16 November 2023 (C-366/22...
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Impact of classification of goods on customs duties - opinion of the Advocate General of the CJEU in case C-104/23
On January 18, 2024, the Advocate General of the Court of Justice of the European Union issued an opinion...
SUP fee - ecology yes, but with VAT?
This year, when selling food or beverages in single-use packaging to consumers, a SUP fee they must be...
TP adjustments - to show or not to show in VAT settlements?
Many companies in capital groups make an annual price adjustment in transactions with a related company...
Factors affecting the tariff classification of goods
The Court of Justice of the European Union (CJEU) confirmed in its judgment of 16 November 2023 (C-366/22...
CBAM – detailed reporting obligations and new guidance from the European Commission
On 17th August, the European Commission published rules governing the implementation of the CBAM mechanism...
Cooperation with influencers through barter
Marketing contracts are an area where, in addition to the legal risks, particular attention should be...
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