Brekel, Ronald van den
VAT effects of year - end transfer pricing adjustments / Ronald van den Brekel, Ad van Doesum & Herman van Kesteren .-- , 2017
Disponible también en línea a través de la Biblioteca del Instituto de Estudios Fiscales. Resumen. Conclusión.
A recurrent topic of debate concerns the effects of transfer pricing adjustments for direct tax purposes on the taxable amount for VAT. This topicis currently gaining attention, which is underlined by the recently published VAT Committee working paper on the possible VAT effects of transfer pricing adjustments. Focussing on so-called .year-end transfer pricing adjustments., the authors discuss various fundamental questions concerning the VAT implications of such adjustments. Do year-end adjustments lead to retroactive adjustments to the taxable amounts for VAT of supplies made throughout the year? If any retroactiveadjustments need to be made to the taxable amounts for VAT, what are the implications for the VAT returns, EC-Sales lists andinterests? What if a year-end adjustment does not lead to an adjustment of the taxable amount for VAT? Can intercompany payments (which follow from year-end adjustments) then be regarded as theremuneration for any service rendered? Or areyear-end adjustments merely to be regarded as financial transactions outside the scope of EU VAT after all? These, and other questions are discussed in this article.
PRECIOS DE TRANSFERENCIA
IMPUESTO SOBRE EL VALOR AÑADIDO
AJUSTES FISCALES
UNION EUROPEA
Doesum, Ad van
Kesteren, Hermanus Willem Maria van
EC Tax Reviewv. 26, n. 4, August 2017, p. 182-192
VAT effects of year - end transfer pricing adjustments / Ronald van den Brekel, Ad van Doesum & Herman van Kesteren .-- , 2017
Disponible también en línea a través de la Biblioteca del Instituto de Estudios Fiscales. Resumen. Conclusión.
A recurrent topic of debate concerns the effects of transfer pricing adjustments for direct tax purposes on the taxable amount for VAT. This topicis currently gaining attention, which is underlined by the recently published VAT Committee working paper on the possible VAT effects of transfer pricing adjustments. Focussing on so-called .year-end transfer pricing adjustments., the authors discuss various fundamental questions concerning the VAT implications of such adjustments. Do year-end adjustments lead to retroactive adjustments to the taxable amounts for VAT of supplies made throughout the year? If any retroactiveadjustments need to be made to the taxable amounts for VAT, what are the implications for the VAT returns, EC-Sales lists andinterests? What if a year-end adjustment does not lead to an adjustment of the taxable amount for VAT? Can intercompany payments (which follow from year-end adjustments) then be regarded as theremuneration for any service rendered? Or areyear-end adjustments merely to be regarded as financial transactions outside the scope of EU VAT after all? These, and other questions are discussed in this article.
PRECIOS DE TRANSFERENCIA
IMPUESTO SOBRE EL VALOR AÑADIDO
AJUSTES FISCALES
UNION EUROPEA
Doesum, Ad van
Kesteren, Hermanus Willem Maria van
EC Tax Reviewv. 26, n. 4, August 2017, p. 182-192