INTRODUCTION
We are pleased to present you our annual year-end tax bulletin
summarising the most relevant current tax developments in the
Netherlands, Belgium, Luxembourg and Switzerland. It also provides
an insight into (ongoing) international developments, mainly at
OECD level, with a focus on developments and changes relevant for
internationally operating businesses.
INTERNATIONAL DEVELOPMENTS
Main changes in international taxation in more detail
"Due to the principal purpose test ("PPT")
effective in many treaty relationships as from 1 January 2020 and
the consequences of the CJEU's so-called Danish cases, MNEs
focus even more on substance and economic reality to ensure treaty
and EU Directive benefits in the future. MNEs not only align their
legal structures with business structures, they also improve their
transfer pricing documentation and prepare for full transparency of
their tax position.