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Knowledge Base: International Tax Guides

De Voorwaarts — TGS Global

Knowledge Hub: International tax, BOI, Pillar Two and transfer pricing guides

Practical guidance on the tax and compliance questions we are asked most often: investing in Thailand, Pillar Two and the global minimum tax, cross-border reporting, transfer pricing and the Dutch rules for director-major shareholders. Every topic opens a short overview with the in-depth articles in that series.

Investing and doing business in Thailand

Industrial manufacturing facility under sunset sky representing Thailand BOI investment incentives

Thailand BOI incentives

Tax holidays, 100% foreign ownership and the 7-step application.
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Calculator, financial records, and notepad illustrating Thailand Pillar Two minimum tax calculations

BOI and Pillar Two

Exemption or the 10% rate? A worked comparison.
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Tax advisor reviewing corporate tax reports and filing schedules on laptop

Thailand Pillar Two: filings and penalties

Thai filings, the DAC9 gap, deadlines and the surcharge.
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Bangkok skyline and waterfront at sunset representing establishing a business in Thailand

Starting a business in Thailand

The 49% rule, nominee checks, capital and employment law.
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Netherlands: director-shareholders

Dutch director-major shareholder in suit reviewing borrowing rules from own BV

Excessive borrowing from your own BV

The € 500,000 limit, and the plan to cut it to € 100,000.
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Digital globe with financial nodes showing cross-border lending and foreign subsidiary loans

Borrowing from a foreign subsidiary

A foreign loan counts too. Currency risk and double taxation.
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Transfer pricing

Financial professional calculating transfer pricing benchmarks on office desk

Transfer pricing for SMEs

Arm’s length prices, Amount B and the documentation you need.
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Logistics manager with digital tablet in warehouse representing baseline marketing and distribution

Amount B in practice

Who is in scope, the pricing matrix and the Dutch position.
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Stack of corporate documentation binders representing the Dutch transfer pricing Master file

Transfer pricing documentation

Master file, local file, CbC report and common mistakes.
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Business executives signing an intercompany loan contract across meeting table

Intercompany loans

Is it a loan? Credit rating, interest rate and the risks.
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DAC6: mandatory disclosure

European Union flags fluttering under blue sky representing EU DAC6 mandatory disclosure directive

DAC6: introduction and scope

When cross-border arrangements must be reported, and by when.
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Global network map with connected financial points representing cross-border arrangement criteria under DAC6

Is my arrangement cross-border?

The five criteria that decide whether DAC6 applies to you.
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Tax hallmarks and legal compliance documentation for the DAC6 main benefit test

Hallmarks and the main benefit test

Categories A to E and when the main benefit test applies.
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Desk with financial charts, graphs, and audit paperwork for DAC6 reporting obligations

Who must report, and when?

The intermediary, the taxpayer and the 30-day deadline.
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Wooden judge gavel on law desk representing legal penalties and tax disclosure compliance

Reporting, penalties and your file

The portal, the fines and what to keep in your file.
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Cannot find what you are looking for?

These guides are a starting point, not advice on your own situation. Contact our international tax specialists and we will look at your case.

Disclaimer The articles in this knowledge base are for information purposes only and are not a substitute for personal advice.
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