Transfer pricing is increasingly influencing significant changes in tax legislation around the world. This issue of Transfer Pricing News focuses on recent developments in the field of transfer pricing in Kuwait, the Netherlands and Switzerland. It also includes an interesting article on country-by-country reporting and an article from BDO Belgium about a conflict of interest between transfer pricing and customs.

1. CONTENTS
▶▶ INTRODUCTION
▶▶ BELGIUM
Transfer pricing and customs: a forced marriage
▶▶ KUWAIT
Key changes relating to transfer pricing impacting
foreign companies operating in Kuwait
▶▶ NETHERLANDS
Tax ruling practice regulations updated
New country-by-country-reporting rules for
banks and investment firms
▶▶ SWITZERLAND
Changes to principal companies requirements
▶▶ UNITED KINGDOM
Transfer pricing reporting
UNITED KINGDOM
Transfer pricing reporting
READ MORE 9
BELGIUM
Transfer pricing and customs: a forced
marriage
READ MORE 2
THE NETHERLANDS
Tax ruling practice regulations updated
READ MORE 6
JULY 2014 ISSUE 15
WWW.BDOINTERNATIONAL.COM
TRANSFERPRICINGNEWS
INTRODUCTION
W
e are very pleased to bring you
this 15th
issue of BDO’s Transfer
Pricing News, which we were able
to produce in close co-operation with our
colleagues from the countries mentioned
below.
Transfer pricing is increasingly influencing
significant changes in tax legislation around
the world. This issue of Transfer Pricing News
focuses on recent developments in the field
of transfer pricing in Kuwait, the Netherlands
and Switzerland. It also includes an interesting
article on country-by-country reporting and an
article from BDO Belgium about a conflict of
interest between transfer pricing and customs.
We trust that you will find it useful and
informative. If you would like more information
on any of the items featured, or would like to
discuss their implications for your business,
please contact the person named under
the item(s). The material discussed in this
newsletter is intended to provide general
information only, and should not be acted upon
without first obtaining professional advice
tailored to your particular needs.

2. 2 TRANSFER PRICING NEWS N° 15
BELGIUMTRANSFER PRICING AND CUSTOMS: A FORCED MARRIAGE
D
ue to globalisation and the ensuing
frequency of international transactions,
the importance of transfer pricing
in the customs environment has significantly
increased. Tax and customs administrations, even
within one country and sometimes within the
same government department, have different
approaches. Specifically, tax authorities focus on
intra-group sales prices that may be perceived
as higher than they should be, while customs
authorities verify imported goods for which
prices may be perceived as lower than the market
price. While both administrations seek to achieve
the same goal, i.e. arm’s length pricing, customs
and tax examinations are forced to follow
different regulations and may have conflicting
interests.
Transfer pricing: basic concepts
The basic principle in transfer pricing is the
arm’s length principle as described in the
OECD Transfer Pricing Guidelines. The transfer
price between related parties impacts the
profitability of the different entities and hence
the tax revenues for the different countries.
Local tax authorities seek conformity with
the “arm’s length principle” for intercompany
transactions in order to safeguard local tax
revenues. The arm’s length principle is based on
the OECD guidelines, which form the basis of
bilateral tax treaties involving OECD member
countries and an increasing number of non-
member countries and states: “[Where]
conditions are made or imposed between the
two [associated] enterprises in their commercial
or financial relations which differ from those
which would be made between independent
enterprises, then any profits which would, but
for those conditions, have accrued to one of the
enterprises, but, by reason of those conditions,
have not so accrued, may be included in the
profits of that enterprise and taxed accordingly.”
The OECD Transfer Pricing Guidelines also
describe specific methods to determine
transfer prices, with the transactional net
margin method being most commonly used.
Finally, many countries have issued guidelines
on the transfer pricing documentation used
to substantiate and justify transfer prices
for goods, services, intangibles, finance
transactions, etc.
Customs valuation: basic concepts
Customs valuation is based on the General
Agreement on Tariffs and Trade (GATT)/World
Trade Organisation (WTO) Valuation Code.
The GATT/WTO Valuation Code definition
of “customs value” forms the basis on which
WTO members have drafted the definition
of customs valuation in their own customs
legislation. In the European Community, the
basic customs valuation rules and definitions
are found in Articles 28-36 of the Community
Customs Code and in Articles 141-181 and
Annexes 23-29 of the Community Customs
Code Implementing Provisions.
In determining the customs value, different
methods are defined which need to be used
in hierarchical order. The primary method is
the transaction value of the imported goods.
Here, the transaction value of imported
goods between related parties can only be
accepted if it can be demonstrated that the
price of the imported goods is at arm’s length.
Furthermore, this transaction value must be
adjusted under certain specific conditions.
Customs and transfer pricing: conflict of
interest
Both tax and customs administrations
often set rules independently for the same
transaction and/or goods. Tax authorities seek
conformity with the OECD Transfer Pricing
Guidelines which have been put in place in
many countries, whereas customs authorities
conform to Article VII of the GATT Valuation
Code.
Identify the main income tax charge
Entity based
Royalties
Overhead
Financing costs
Selling price
Marketing
costs
Compensation
payments
Provided
materials
Management
fees
Identify the main customs charge
Product based
Transfer pricing view Valuation view

3. 3TRANSFER PRICING NEWS N° 15
This different approach to transfer pricing
and valuation creates an atmosphere of
uncertainty and complexity. It also leads to
increased implementation and compliance
costs, an absence of flexibility in conducting
business operations, and last but not least
creates a significant risk of penalties. In
fact, even when a company complies with
both the OECD guidelines/principles and
the WTO Valuation Agreement there is no
guarantee that there will not be a dispute
between two countries or two administrations
in the same country regarding the
determination of the arm’s length price. This
means that valuation conflicts can arise not
only prior to, but also after, an audit.
Given the significant increase in the volume
and complexity of intercompany transactions,
the divergence in customs and transfer
pricing valuation presents an obstacle to
the liberalisation of trade and it inhibits
international development for companies of
all sizes.
The table below provides a summary of the
factors highlighting the differences between
transfer pricing and customs valuation.
Factor Transfer pricing Customs valuation
Taxable event Sale or purchase of the goods Importation of goods into the country
Rationale Avoiding shifting of income Modelling of international trade
Relevant time for assessing value Date of sale or purchase Date of importation
Time of audit Year(s) after the sale transaction Time of importation or years after the transaction
Goals pursued by authorities Decrease in value Increase in value
Customs
Parent company
Income tax question
Is TP arm’s length?
BE perspective
TP too high?
From USA perspective
TP too low?
Sales tax question
From BE perspective:
Import VAT, delivery of tangible goods taxable?
Input tax deduction authorization?
Customs question
Is the delivery subject to customs?
If so: what is the appropriate customs value?
BE perspective
TP (as customs value) too low?
SubsidiaryDelivery TP = 100
Conflict of interest

4. 4 TRANSFER PRICING NEWS N° 15
Case study
A common situation where transfer pricing may
trigger customs issues relates to a retrospective
adjustment of the transfer price paid for goods
in a cross-border situation. Suppose you are
a company acting as a limited risk distributor
based in China and you purchase and import
goods from a related company in Belgium.
The distribution activities will be remunerated
using the transactional net margin method
with a target operating margin on sales. At the
beginning of the year, the transfer prices will be
set based on budgets provided by the Chinese
entity. Hence, products will be imported based
on the budgeted transfer price.
Schematic overview of the flows:
Customer
Principal Co Limited risk
distributor
Residual profit
Target operating margin
Physical flow
Invoice flow
Service flow
Bookkeeping services
Sale of finished goods
At the year-end (or more frequently), a transfer
pricing adjustment is made to bring the actual
operating margin realised by the Chinese
distributor in line with the target operating
margin.
From a customs point of view, the year-
end adjustment will involve a correction to
the declared customs value of the import
transactions affected by the year-end
adjustments. If the price is adjusted upwards,
both the customs value and the amount of
customs duties will increase. If the price is
adjusted downwards, the effect will be the
opposite: both the customs value and the
amount of customs duties will decrease. In
the former situation, the customs authorities
will expect a regularisation of the declared
customs values and additional customs duties
to be paid. In the latter situation, the importer
may be entitled to a refund of customs duties.
Furthermore, in such cases of structural year-
end adjustments it is advisable to conclude a
customs valuation agreement with customs
to agree on the frequency, timing and
methodology for these adjustments.
Conclusion
Two different valuation regimes applicable
to the same transactions forces importers to
take into account the consequences of transfer
pricing methodologies when assessing customs
valuation. It is highly recommended to review
pricing methodologies and agree with the
customs administration on the procedure to
be used to reassess or confirm the customs
valuation of imports in an efficient and
compliant manner.
By Pieter Haesaert, customs expert and
by Tine Slaedts, transfer pricing partner at
BDO Belgium.
Your BDO contacts in Belgium:
TINE SLAEDTS
tine.slaedts@bdo.be

5. 5TRANSFER PRICING NEWS N° 15
KUWAITKEY CHANGES RELATING TO TRANSFER PRICING IMPACTING FOREIGN COMPANIES OPERATING IN KUWAIT
T
he Kuwait Income Tax Department
recently issued a revised set of Executive
Rules and Regulations (the Executive
Rules) which apply for tax periods ending on
31 December 2013 and thereafter. The revised
Executive Rules include the following changes
relating to transfer pricing which will affect
foreign companies operating in Kuwait.
–– Deductions for imported materials will be
restricted as follows:
a) Materials imported from head office: a
maximum of 85% of the corresponding
revenue from the imported materials
(previous limit was 85% to 90% of
corresponding revenue).
b) Materials imported from related entities:
a maximum of 90% of the corresponding
revenue from the imported materials
(previous limit was 90% to 93.5% of
corresponding revenue).
c) Materials imported from third parties: a
maximum of 95% of the corresponding
revenue from the imported materials
(previous limit was 93.5% to 96.5% of
corresponding revenue).
–– Deductions for the cost of design work
carried out outside Kuwait will be limited to:
a) 75% of the design revenue, for design
work carried out by head office
(previously the limit was 75% to 80%).
b) 80% of the design revenue, for design
work carried out by related entities
(previously the limit was 80% to 85%).
c) 85% of the design revenue, for design
work carried out by third parties
(previously the limit was 85% to 90%).
–– Deductions for the cost of consultancy work
carried out outside Kuwait will be limited to:
a) 70% of the consultancy revenue for
costs related to work carried out at the
head office (previously the limit was
70% to 75%).
b) 75% of the consultancy revenue for
costs related to work carried out by
related entities (previously the limit was
75% to 80%).
c) 80% of the consultancy revenue for
costs related to work carried out by
third parties (previously the limit was
80% to 85%).
–– Deductions for lease/rental costs of assets
leased from the head office, subsidiaries
and related entities will be limited to the
depreciation charge on the corresponding
assets, based on the tax depreciation rates
specified in the Kuwait tax regulations.
Your BDO contact in Kuwait:
QAIS M. AL NISF
qais.alnisf@bdo.com.kw
Your BDO contacts in Kuwait:
RAMI ALHADHRAMI
rami.alhadhrami@bdo.com.kw

6. 6 TRANSFER PRICING NEWS N° 15
NETHERLANDSTAX RULING PRACTICE REGULATIONS UPDATED
O
n 12 June 2014 the Dutch Ministry
of Finance released five decrees as
an update to the existing 2004 tax
ruling policies. These include decrees relating
to substance requirements, advance pricing
agreement (APA) requests and advance tax
ruling (ATR) requests. The decrees are in line
with the 2004 tax ruling policies. We highlight
the key points below.
1. Substance requirements
Since 2004 there has been a policy decree
on the basic substance requirements for
Dutch intermediary companies engaged in
intra-group royalty and financing activities.
The 2004 decree applied to financial services
entities seeking an ATR or wishing to conclude
an APA with the Dutch tax authorities.
From 1 January 2014, the Dutch substance
rules for financial services entities have
been laid down in Dutch tax law. These
basic substance requirements are now also
applicable for financial services companies that
do not seek prior confirmation by means of
an APA or ATR with the Dutch tax authorities,
but wish to make use of the Dutch tax treaty
network or the EU Interest & Royalty Directive
(including its local implementation).
The new decrees follow the extended financial
service company definition as applicable for the
basic substance requirements. This implies that
companies, 70% or more of whose activities
consist of intercompany financing, licensing,
rental and leasing, are considered financial
service companies. The new policy decrees give
some further guidance on the interpretation
of these basic substance requirements. Some
important aspects are listed below.
–– Supervisory directors can be excluded in
determining whether or not at least half of
the directors are Dutch resident;
–– The requirement that board decisions
are taken in the Netherlands implies that
regular board meetings must be held in the
Netherlands with the physical presence of
directors. During these meetings important
decisions must be made. The decision
making process must go beyond the mere
formalisation of decisions already taken
outside the Netherlands;
–– As regards bank accounts, it is not required
that they are held with a Dutch (resident)
banking institution;
–– Under the basic substance requirements
the book-keeping should be done in the
Netherlands. If the group operates a
centralised bookkeeping function, the
substance requirements can still be met if
there are sufficient operational activities in
the Netherlands.
2. APA/ATR
The requirements for concluding an APA/
ATR are in line with the 2004 ruling policies.
An APA/ATR may now apply for a longer term
(5 years); this may be extended in the case
of long term contracts. To be able to apply
for an APA or an ATR a company must meet
the basic substance requirements or have the
genuine intention to meet these requirements.
For financial service companies applying for
an APA there is an additional element. If such
companies only meet the basic substance
requirements and the group does not have any
other activities in the Netherlands, nor does
the group have any genuine plans to increase
their substance in the Netherlands, then the
Dutch tax authorities will spontaneously
exchange information about the APA.
Requests for an ATR and an APA need to be
filed with the competent tax inspector of
the taxpayer, with a copy of the request to
be sent to the APA/ATR Team in Rotterdam.
The new decree on the ATR explicitly lists
eight situations in which the competent tax
inspector needs to request binding advice from
the APA/ATR Team in Rotterdam. A binding
advice is required for:
–– Application of the participation exemption
for intermediate holding companies and top
holding companies with subsidiaries without
any business activities in the Netherlands;
–– Hybrid financing or hybrid entities in
international structures;
–– Confirmation whether there is a permanent
establishment in the Netherlands or
the BES Islands (Bonaire, Saba and
Sint Eustatius);
–– Substantial interest for non-resident
taxpayers;
–– Allocation of shares to a permanent
establishment in the Netherlands or the
BESIslands;
–– Confirmation whether there is a Dutch
business enterprise under the rules for non-
resident taxpayers;
–– Dutch dividend withholding tax position for
Cooperatives.
–– The application of discretionary relief
(“vangnetbepaling”) under any Limitation of
Benefits articles in a bilateral tax treaty also
needs to be filed with the APA/ATR Team in
Rotterdam as well.
The new decrees apply from 13 June 2014.
Your BDO contact in the Netherlands:
HANS NOORDERMEER
hans.noordermeer@bdo.nl
Your BDO contact in the Netherlands:
SJOERD HARINGMAN
sjoerd.haringman@bdo.nl

7. 7TRANSFER PRICING NEWS N° 15
NEW COUNTRY-BY-COUNTRY-REPORTING RULES FOR BANKS AND INVESTMENT FIRMS
T
he European Capital Requirements
Directive (2013/36/EU), published
in 2013, introduced a new governance
framework for the supervision of banks and
the Basel III capital requirements to European
law. In order to incorporate these regulations
into Dutch law, a decree has been drafted
and submitted to the Second Chamber of
Parliament on 28 April 2014.
Under the decree, the following information
should be reported on a country-by-country
basis:
1. Name, nature of activities and geographical
location;
2. Revenue;
3. Average number of full-time employees;
4. Profit or loss before tax;
5. Tax on the profit or loss; and
6. Government subsidies received.
If possible, this information should be
published together with the annual accounts or
the consolidated accounts of the entity either
included in the accounts or with a reference to
where and when this information is published.
This decree suggests country-by-country
reporting for banks and investment firms
whose accounting year started on or after
1 January 2014.
In addition to this, the following information
has to be published/submitted by 1 July 2014
regarding the previously closed accounting year
(on or after 1 January 2013):
–– Banks and investment firms have to publish
information regarding point 1, 2 and 3 above;
and
–– Banks or investment firms which have been
registered by the Financial Stability Board
as globally system-relevant are required to
provide information on the above points 4, 5
and 6 on a confidential basis to the European
Commission and the Dutch Central Bank.
Another requirement in the decree is the
publishing of the return on assets, i.e. the
net realised profit on the total assets,
for accounting years starting on or after
1 January 2014, which also applies to statutory
accounts.
The introduction of country-by-country
reporting (“CBCR”) for banks and investment
firms is one of numerous regulations for more
financial supervision on a global basis. Broader
CBCR requirements will follow considering
the OECD Discussion Draft on Transfer
Pricing Documentation and Country-by-
Country requirements which was published
on 30 January 2014 as one of the actions of
the OECD against base erosion and profit
shifting. CBCR should give tax authorities an
additional risk assessment tool to understand
the financials of multinationals and where their
key value drivers are located. The OECD plans
to publish final country-by-country reporting
rules in autumn 2014 for the local countries to
incorporate them into national law.
These developments are moving fast and tax
payers are advised to start getting prepared
for the additional compliance requirements
and ensure that their transfer pricing model
(transactions between and arm’s-length
remuneration of group entities) is in line with
their business model.
Your BDO contact in the Netherlands:
SJOERD HARINGMAN
sjoerd.haringman@bdo.nl
Your BDO contact in the Netherlands:
CARINA ROMANO
carina.romano@bdo.nl

8. 8 TRANSFER PRICING NEWS N° 15
SWITZERLANDCHANGES TO PRINCIPAL COMPANIES REQUIREMENTS
T
he Swiss Federal Tax Administration
(SFTA) has issued new instructions to
the Swiss cantons on the tax treatment
of principal company structures, which
include a Swiss principal company and foreign
distribution companies. Under the principal
company regime, a percentage of profits is
not subject to Swiss tax, and the SFTA wishes
to prevent abuse of the profit allocation
mechanism.
New rules
The main new requirements are that:
–– Affiliated foreign distributors must distribute
goods exclusively on behalf of the principal
company, and must be economically
dependent on it, which will be the case if
at least 90% of their income relates to the
principal company’s business;
–– The gross margin of distributors must not
exceed 3% of sales or higher costs; and
–– Key trading functions and risks must be
allocated to the principal company, and not
outsourced.
Implications
The new requirements must be met by 2015/16
for existing principal companies, but they are
immediately effective for all new applications.
If the new requirements are not met, the
effective tax rate may be increased, reducing
the benefit of the principal company regime.
In the case of existing principal companies,
failure to meet the new requirements could
result in adjustments for previous years.
Action required
The cantons will be reviewing principal
company structures, and deciding whether any
tax rulings need to be amended, or changes
need to be made to arrangements if a structure
is to comply with the new rules. Existing and
proposed principal companies will therefore
need to review distributors’ activities and gross
margins, and the allocation of key functions
and risks, and make any necessary changes
in order to continue to qualify for principal
company treatment.
Your BDO contacts in Switzerland:
THOMAS KAUFMANN
thomas.kaufmann@bdo.ch

9. 9TRANSFER PRICING NEWS N° 15
UNITEDKINGDOMTRANSFER PRICING REPORTING
T
he Organisation for Economic Co-
operation and Development (OECD)’s
planned introduction of country-by-
country reporting and stricter transfer pricing
documentation requirements will greatly
increase the transparency of businesses’ value
chains. It will also mean that businesses will
need to compile the required data effectively.
Action is recommended now to test reporting
capabilities and maximise the time to address
shortcomings and potential tax exposure.
Background
The OECD recently released its updated
discussion draft on Transfer Pricing
Documentation and Country-by-Country
Reporting as part of its ongoing review of
base erosion and profit shifting (BEPS) in the
international tax system. This will result in a
major change in the way that multinational
enterprises (MNEs) document their transfer
pricing policies. These proposals will:
–– Greatly increase transparency for local tax
authorities through the inclusion of country-
by-country (CbC) reporting of key financial
metrics across a group; and
–– Raise the bar for the level of analysis required
in transfer pricing documentation and the
frequency of its review and updating.
As documentation is a key part of transfer
pricing risk assessment, meeting these
requirements will be critical to preventing
or rebutting more onerous tax enquiries or
audits and the transfer pricing adjustments or
penalties that could result.
Country-by-country reporting
MNEs will be expected to report specified
business and financial data by country and
entity following a template proposed by
the OECD. This will include:
–– Classification of business activities
–– Revenues
–– Earnings before income tax
–– Income taxes paid on a cash basis (to local
and other countries)
–– Withholding tax paid
–– Stated capital and accumulated earnings
–– Number of local employees and related total
employee costs
–– Tangible assets
–– Intercompany payments and receipts of
royalties, interest and service fees.
The OECD may add to this list as part of its
consultation process.
Providing immediate visibility of how a local
entity performs within a group, the respective
importance of its local personnel in terms of
average reward, and the size and direction of its
intercompany transactions will make it easier
for tax authorities to identify and challenge
potential weaknesses. It will allow tax
authorities to assess risk by using a comparison
of country results or applying a formulaic
approach at the expense of the arm’s length
standard.
Businesses will need to be confident that:
–– Transfer pricing policies are set appropriately
and any variations between entities are
addressed and supported;
–– Policies are implemented effectively and that
local results are in line with expectations;
and
–– It is possible and practical to meet these
reporting requirements, for example that
accounting systems can provide quality data
in a timely way.
CbC requirements will not be limited to large
MNEs. Tax authorities will have the ability to
request CbC reporting from SMEs as part of
their risk assessment or tax audit procedures.
Transfer pricing documentation
The OECD seeks transfer pricing
documentation that is comprehensive for
tax authority risk assessment purposes.
The existing standard in Chapter V of the
OECD Guidelines on Transfer Pricing is,
therefore, being replaced. The proposed key
changes include:
–– An emphasis on contemporaneous
documentation rather than “justifications
for positions after the fact”, requiring
the preparation of documentation and
supporting evidence in advance of the filing
of the tax return – in practice twelve months
from the year end;
–– An understanding that all relevant
documents in an MNE’s possession will be
available on the request of tax authorities,
regardless of whether it is in the possession
of the local entity;
–– A two-tier approach of a central ‘masterfile’
and supporting local country files, alongside
CbC reporting increasing the transparency of
the global position for local tax authorities;
–– An assumption of annual review and update
of transfer pricing documentation, with an
expectation of a three-yearly refreshing of
comparables benchmarking in the absence of
business changes in the interim;
–– An assertion that local comparables should
be used where reasonably available, rather
than regional comparable data; and
–– The provision of additional specified
information.
The OECD is keen for tax authorities to focus
on the materiality of transactions, although
this is currently set out in terms of the size
of the local economy as well as materiality
for the business. This is a clear indication
that tax authorities are focusing on a more
stringent review at the risk assessment stage
of a transfer pricing enquiry and that their
expectations for compliance will be higher than
at present. Robust documentation will be a
critical part of achieving a low-risk rating and
preventing more detailed enquiries.
Recommendations
Although the OECD’s proposals are in
draft at present, significant changes before
implementation are unlikely. Based on
the OECD’s Base Erosion and Profit Shifting
Action Plan, the proposals will be finalised
by September 2014, and we expect that tax
authorities will require them to be followed
for subsequent tax return filings. So we
recommend that businesses:
–– Test and confirm the ability of their systems
to meet CbC reporting requirements;
–– Conduct a ‘dry run’ of CbC reporting to
review the outputs for unintended or
unexpected outcomes and tax and transfer
pricing risk; this might be combined with
wider process testing, for example for Senior
Accounting Officer purposes;
–– Address any shortcomings identified in
the group’s transfer pricing policy and
implementation ahead of the tax filing
process;
–– Test existing documentation against
the updated masterfile and countryfile
requirements of the Draft;
–– Ensure that comparables analysis and
benchmarking data is up to date; and
–– Put in place an implementation programme
for local country files where these do not
already exist.
Where these actions identify potential
weaknesses in the business’ transfer pricing
policy, implementation or documentation,
steps should be taken to address these at the
earliest opportunity. Effective remedies may
not be possible if this is left until the tax return
filing process following the year end.
Your BDO contact in United Kingdom:
ANTON HUME
anton.hume@bdo.co.uk
Your BDO contact in United Kingdom:
DUNCAN NOTT
duncan.nott@bdo.co.uk

10. 10 TRANSFER PRICING NEWS N° 15
This publication has been carefully prepared, but it has been written
in general terms and should be seen as broad guidance only. The
publication cannot be relied upon to cover specific situations and you
should not act, or refrain from acting, upon the information contained
herein without obtaining specific professional advice. Please contact
the appropriate BDO Member Firm to discuss these matters in the
context of your particular circumstances. Neither the BDO network,
nor the BDO Member Firms or their partners, employees or agents
accept or assume any liability or duty of care for any loss arising from
any action taken or not taken by anyone in reliance on the information
in this publication or for any decision based on it.
BDO is an international network of public accounting firms, the BDO
Member Firms, which perform professional services under the name
of BDO. Each BDO Member Firm is a member of BDO International
Limited, a UK company limited by guarantee that is the governing
entity of the international BDO network. Service provision within the
BDO network is coordinated by Brussels Worldwide Services BVBA, a
limited liability company incorporated in Belgium with its statutory
seat in Brussels.
Each of BDO International Limited, Brussels Worldwide Services BVBA
and the member firms of the BDO network is a separate legal entity and
has no liability for another such entity’s acts or omissions. Nothing in
the arrangements or rules of the BDO network shall constitute or imply
an agency relationship or a partnership between BDO International
Limited, Brussels Worldwide Services BVBA and/or the member firms
of the BDO network.
BDO is the brand name for the BDO network and for each of the BDO
Member Firms.
© Brussels Worldwide Services BVBA, July 2014 1407-04
LIST OF CONTACT PERSONS
Dan McGeown
International Tax Department
BDO Toronto
Tel
Fax
e-mail
+1 416 369 3127
+1 416 865 0887
dmcgeown@bdo.ca
Dirk Elbert
International Tax Department
BDO Frankfurt am Main
Tel
Fax
e-mail
+49 69 95 941 438
+49 69 95 941 326
dirk.elbert@bdo.de
Michiko Hamada
International Tax Department
BDO New York
Tel
Fax
e-mail
+1 212 885 8577
+1 212 697 1299
mhamada@bdo.com
Sjoerd Haringman
International Tax Department
BDO Rotterdam
Tel
Fax
e-mail
+31 10 242 4600
+31 10 242 4624
sjoerd.haringman@bdo.nl
Anton Hume
International Tax Department
BDO London
Tel
Fax
e-mail
+44 207 486 5888
+44 207 487 3686
anton.hume@bdo.co.uk