About memento

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So far memento has created 68 blog entries.

Tax Alert: New TP Guidelines

Yesterday, the January 2022 update of the OECD Transfer Pricing Guidelines has been published. The update incorporates TP guidance on 3 subjects on which reports were published in recent years.


NL Tax Alert: ATAD2 Decree

Today, the Dutch government issued a decree on the anti-hybrid rules (ATAD2). The decree confirms that the dual inclusion escape may apply for two specific situations involving (a.) a Dutch entity in a US REIT structure and (b.) a Dutch entity classifying as ‘partnership’ from a US tax perspective.