Dick Hofland in Management Team magazine on the European harmonisation of corporation tax
The debt crisis cuts across a development which has long occupied the international tax world: the harmonisation of European corporation tax, or the Common Consolidated Corporate Tax Base (CCCTB). Companies must currently file a separate tax return in each country where they are active. This leads to significant adminstrative burdens and discussions about where profits should be taxed. Governments and companies both want to be free of this cat and mouse game. "Multinationals do not want separate discussions with 27 different governments," says Dick Hofland, tax lawyer and partner at De Brauw Blackstone Westbroek. "They do not want to overpay, yet at the same time they do want clarity about how much they have to pay, and where."
Dick Hofland also gives his view in Management Team on the horizontal supervision arrangements between the Dutch tax administration and Dutch taxpayers. These arrangements provide that taxpayers voluntarily assume compliance obligations relating to the manner and timing of the submission and the quality of information that is provided. In return, the tax administration commits itself to respond promptly to requests from the taxpayer for certainty in advance about technical issues by the issuance of tax rulings. Dick Hofland observes a growing trend that the tax administration tends to respond too slowly to requests for rulings or refuses to express an opinion. Another disadvantage of horizontal supervision is that disputes are less frequently submitted to the tax courts but end in settlements out of court. As a result, on crucial issues, no new case law develops that can provide guidance to all taxpayers.
To read the article, please click here. The article is available in Dutch only