Michiel Voet

We’re excited to expand our strategic collaboration with Envisio! Together, Baker Tilly’s advisory services and Envisio’s cloud-based platform deliver an integrated strategy and performance solution that helps governments, schools and not-for-profits: → Align strategy with execution → Track progress in real time → Strengthen accountability → Deliver better community outcomes Learn more: https://bit.ly/4mGp514

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𝐏𝐀𝐍𝐄𝐋 𝐃𝐈𝐒𝐂𝐔𝐒𝐒𝐈𝐎𝐍 – 𝐀𝐈 𝐚𝐧𝐝 𝐀𝐮𝐭𝐨𝐦𝐚𝐭𝐢𝐨𝐧: 𝐓𝐫𝐚𝐧𝐬𝐟𝐨𝐫𝐦𝐢𝐧𝐠 𝐈𝐧𝐝𝐢𝐫𝐞𝐜𝐭 𝐓𝐚𝐱 As indirect tax functions face growing complexity—shifting regulations, data overload, and limited resources—businesses are increasingly embracing AI and automation to streamline compliance and reduce manual effort. At the 𝟗𝐭𝐡 𝐀𝐧𝐧𝐮𝐚𝐥 𝐒𝐭𝐫𝐚𝐭𝐞𝐠𝐢𝐜 𝐈𝐧𝐝𝐢𝐫𝐞𝐜𝐭 𝐓𝐚𝐱 & 𝐕𝐀𝐓 𝐌𝐚𝐧𝐚𝐠𝐞𝐦𝐞𝐧𝐭 𝐅𝐨𝐫𝐮𝐦, 11–12 September 2025, #Amsterdam, Netherlands, this panel will explore: 🔹 Practical use cases where automation is driving efficiency 🔹 The challenges and limitations businesses must navigate 🔹 How to apply AI responsibly in tax functions without compromising data privacy Moderator: Daniela Lavin, Chief Tax Officer, BRINTA Panelists: Ravi Dhaliwal, CA, Tax Technology Director, Fonoa Lisa Dowling, Chief Tax & Compliance Officer, Fintua Ioan Sabau, ACCA, PMP, Senior Manager Global Tax, Technology and Indirect Tax, Goodyear Oscar Valdelvira de la Mata, Head of Partnerships & Alliances, Marosa Rik P., Global Account Executive Thomson Reuters Learn more: https://lnkd.in/dE6Pfgkt #IndirectTax #Automation #AIinTax #Amsterdam2025 #TBMGroup #TBMConference

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📣We are pleased to announce that Ryan has expanded its reach and expertise in Europe with the acquisition of European VAT Desk, a Belgium-based tax consultancy firm. Key service areas will include: ✅ VAT compliance with end-to-end VAT management  ✅ In-depth VAT consulting, including complex case analysis, VAT audits, and more This acquisition complements Ryan’s current VAT services, adding a team of experts with more than two decades of experience in the industry.  Learn more: https://lnkd.in/ggu-NdzJ 

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🔍💥 𝗩𝗔𝗧 𝗺𝗲𝗲𝘁𝘀 𝗧𝗿𝗮𝗻𝘀𝗳𝗲𝗿 𝗣𝗿𝗶𝗰𝗶𝗻𝗴: 𝗘𝘂𝗿𝗼𝗽𝗲 𝗱𝗿𝗮𝘄𝘀 𝘁𝗵𝗲 𝗹𝗶𝗻𝗲 For years, CFOs and tax directors have treated transfer pricing as a 𝘥𝘪𝘳𝘦𝘤𝘵 𝘵𝘢𝘹 𝘴𝘵𝘰𝘳𝘺. But the CJEU is now telling us loud and clear: 𝘁𝗿𝗮𝗻𝘀𝗳𝗲𝗿 𝗽𝗿𝗶𝗰𝗶𝗻𝗴 𝗮𝗹𝘀𝗼 𝗺𝗮𝘁𝘁𝗲𝗿𝘀 𝗳𝗼𝗿 𝗩𝗔𝗧. 📌 𝗔𝗿𝗰𝗼𝗺𝗲𝘁 (𝗔𝗚 𝗢𝗽𝗶𝗻𝗶𝗼𝗻, 𝟯 𝗔𝗽𝗿𝗶𝗹 𝟮𝟬𝟮𝟱, 𝗖-𝟳𝟮𝟲/𝟮𝟯) The Advocate General advised that: 👉 Contractually agreed 𝗧𝗣 𝗮𝗱𝗷𝘂𝘀𝘁𝗺𝗲𝗻𝘁𝘀 (e.g. year-end equalisation payments under TNMM) 𝗰𝗮𝗻 𝗯𝗲 𝗩𝗔𝗧𝗮𝗯𝗹𝗲 𝗰𝗼𝗻𝘀𝗶𝗱𝗲𝗿𝗮𝘁𝗶𝗼𝗻 𝗳𝗼𝗿 𝗶𝗻𝘁𝗿𝗮-𝗴𝗿𝗼𝘂𝗽 𝘀𝗲𝗿𝘃𝗶𝗰𝗲𝘀. 👉 Invoices alone aren’t enough: tax authorities may demand 𝗼𝗯𝗷𝗲𝗰𝘁𝗶𝘃𝗲 𝗽𝗿𝗼𝗼𝗳 (activity reports, deliverables, etc.). ⚠️ Bottom line: TP year-end settlements may trigger VAT reporting, reverse charge, corrections — 𝗮𝗻𝗱 𝗲𝘃𝗲𝗻 𝗹𝗲𝗮𝗸𝗮𝗴𝗲 where VAT is non-recoverable. 📌 𝗛𝗼𝗴𝗸𝘂𝗹𝗹𝗲𝗻 (𝗝𝘂𝗱𝗴𝗺𝗲𝗻𝘁, 𝟯 𝗝𝘂𝗹𝘆 𝟮𝟬𝟮𝟱, 𝗖-𝟴𝟬𝟴/𝟮𝟯) The Court ruled that: 👉 A holding company charging 𝗼𝗻𝗲 “𝗰𝗼𝘀𝘁-𝗽𝗹𝘂𝘀” 𝗳𝗲𝗲 𝗳𝗼𝗿 𝗺𝘂𝗹𝘁𝗶𝗽𝗹𝗲 𝘀𝗲𝗿𝘃𝗶𝗰𝗲𝘀 (management, finance, real estate, IT, HR) 𝗰𝗮𝗻𝗻𝗼𝘁 𝗯𝗲 𝘁𝗿𝗲𝗮𝘁𝗲𝗱 𝗮𝘀 𝗼𝗻𝗲 𝘂𝗻𝗶𝗾𝘂𝗲 𝘀𝗲𝗿𝘃𝗶𝗰𝗲. 👉 Authorities must assess 𝗲𝗮𝗰𝗵 𝘀𝗲𝗿𝘃𝗶𝗰𝗲 𝘀𝘁𝗿𝗲𝗮𝗺 𝘀𝗲𝗽𝗮𝗿𝗮𝘁𝗲𝗹𝘆 and look first for 𝗰𝗼𝗺𝗽𝗮𝗿𝗮𝗯𝗹𝗲𝘀. 👉 Only if no comparable exists can they fall back on 𝗳𝘂𝗹𝗹 𝗰𝗼𝘀𝘁. ❌ Blanket “total cost = open market value” approaches are off the table. 💡 𝗪𝗵𝘆 𝘁𝗵𝗶𝘀 𝗺𝗮𝘁𝘁𝗲𝗿𝘀? VAT and TP are converging. The “𝗮𝗿𝗺’𝘀 𝗹𝗲𝗻𝗴𝘁𝗵” and “𝗼𝗽𝗲𝗻 𝗺𝗮𝗿𝗸𝗲𝘁 𝘃𝗮𝗹𝘂𝗲” concepts overlap but 𝗱𝗼𝗻’𝘁 𝗮𝗹𝗶𝗴𝗻 𝗽𝗲𝗿𝗳𝗲𝗰𝘁𝗹𝘆. Result: multinationals face 𝗱𝗼𝘂𝗯𝗹𝗲 𝗰𝗼𝗺𝗽𝗹𝗶𝗮𝗻𝗰𝗲 𝗽𝗿𝗲𝘀𝘀𝘂𝗿𝗲 — TP files are no longer enough, you need 𝗩𝗔𝗧-𝗽𝗿𝗼𝗼𝗳 𝘀𝗲𝗿𝘃𝗶𝗰𝗲 𝗱𝗼𝗰𝘂𝗺𝗲𝗻𝘁𝗮𝘁𝗶𝗼𝗻 𝗮𝗻𝗱 𝗖𝗨𝗣 𝗮𝗻𝗮𝗹𝘆𝘀𝗶𝘀 too. ⏳ 𝗪𝗵𝗮𝘁 𝘁𝗼 𝗱𝗼 𝗻𝗼𝘄? • Map your intra-group service streams. • Evidence reality: contracts, reports, deliverables. • Test for comparables before defaulting to cost-plus. • Align TP adjustments with VAT invoicing (reverse charge, credit notes, return corrections). The VAT/TP debate is just heating up 🔥 — and the 𝗖𝗝𝗘𝗨 𝗶𝘀 𝗽𝘂𝘁𝘁𝗶𝗻𝗴 𝗶𝗻𝘁𝗿𝗮-𝗴𝗿𝗼𝘂𝗽 𝗮𝗿𝗿𝗮𝗻𝗴𝗲𝗺𝗲𝗻𝘁𝘀 𝘂𝗻𝗱𝗲𝗿 𝘁𝗵𝗲 𝗺𝗶𝗰𝗿𝗼𝘀𝗰𝗼𝗽𝗲. #VAT #TransferPricing #CJEU #Arcomet #Högkullen #IndirectTax #TaxStrategy #MNEs #Compliance #TaxControversy Fieldfisher Belgium École Supérieure des Sciences Fiscales (ICHEC-ESSF)

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 📖PwC Global Tax Policy on "Global Minimum Tax and International Investment Treaties: Risks & Opportunities". Together with Maarten Maaskant and other colleagues from PwC, I have prepared the Tax Policy Alert which provides insights of relevance to strategically manage the interactions between global minimum tax (GMT) and international investment agreements (IIAs). The attached file can help to optimize investment outcome, investment attractiveness, risk profile, reputational exposure and compliance in face of enlarging number of states across the world with GMT in force. The interplay between the GMT and IIAs is of significant relevance for multinational groups and states for (i) legal (certainty and protection) and (ii) monetary reasons: (i) IIAs (international law) override the GMT (domestic law) in most jurisdictions. Even if constitutional law allows for treaty override, customary international law (CIL) generally provides that the domestic laws should respect these international obligations. Any conflict between the GMT and IIAs is open to cross border litigation or arbitration; (ii) Tensions between the GMT and IIAs may affect the investment climate of states, discourage investors and increase the price of contemplated projects. The most vulnerable are low-income developing countries insofar as the GMT directly affects the rationale of special economic zones (most often found in these countries) that provide tax holidays (0% of effective tax rate) for foreign investors. Such insights are currently very important, not least because of the US-G7 agreement to pursue a “side-by-side” approach between the GMT and the US tax rules, and the Belgian Constitutional Court decision of 17 July 2025 which refers the Undertaxed Profits Rule (UTPR) to the Court of Justice of the European Union. Both of these developments may have an impact on the extent to which the GMT influences (particularly US) multinationals ROI, and therefore the taxpayer’s legitimate expectations under the relevant IIA. Thank you so much to Will Morris, Edwin Visser, Patrick Brown, Chloe Fox, and Nangel Kwong for reviewing drafts of this contribution. This significantly increased its readability and precision.

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