KPMG road2 indiaxl_7nov2017

Road2IndiaXL
TaxandRegulatory
Session
7 November 2017
NBC Congrescentrum, Nieuwegein

Agenda
1. Why India – our experience
2. Tax and Regulatory Snapshot
3. Possible Sales Presence in India
4. Tax and Non-Tax Incentives
5. Tax and Regulatory Recent Updates
6. KPMG’s Role in India / India Team CV’s
Contact:
Cees van der Helm
Partner
KPMG Meijburg & Co
Mobile: +31 6 2120 1009
Direct: +31 (0) 88 909 1577
E-mail: VanderHelm.Cees@kpmg.com
Mohamed Arichi
Senior Manager
KPMG Meijburg & Co
Mobile: +31 6 1537 2628
Direct: +31 (0) 88 909 1053
E-mail: Arichi.Mohamed@kpmg.com

© 2017 Meijburg & Co, Tax Lawyers, is an association of limited liability companies under Dutch law, registered under Chamber of Commerce registration number 53753348
and is a member of KPMG International Cooperative ("KPMG International"), a Swiss entity. All rights reserved.
4
WhiletheIndiaopportunityisstillreal
7.5%
Growth
India 2.9%
World
33%
FDIinflow
USD 60bn
3
Investor
confidence
3-year average
growth forecast
7.5%
Growingconsumption
demand
60%
30.5%
Paceofdigitisation
AnnualInternetuser
growthin2015-16 ` `
``
`
`
40 Financial
marketstability
(Globalcompetitiveness
ranking2017-18)
FDI in FY’16-17
2016 A.T. Kearney Foreign Direct Investment Confidence Index
WEF Global Competitiveness Report 2016-17
KPMG in India analysis 2017
http://www.worldbank.org/en/publication/global-economic-
prospects#data
1.68
2018

5
WhiletheIndiaopportunityisstillreal
3Investor
confidence
1.68
40Financial
marketstability
(Globalcompetitiveness
ranking2017-18)
FD 1/11 – Modi maakt zaken
doen in India gemakkelijker
De Wereldbank stelt de index samen op
basis van tien criteria. In India
verbeterde de score van acht hiervan.
Het land deed het al goed wat betreft
elektriciteit en leningen krijgen, maar
onder meer het beginnen van een
bedrijf, het betalen van belastingen en
het krijgen van een bouwvergunning
waren erg ingewikkeld. Regels voor al
deze praktijken werden versimpeld.
Wat betreft het gemak belasting te
betalen steeg India 53 plekken, tot 119,
nadat in juli een nieuw stelsel van
omzetbelasting werd ingevoerd. De
index heeft zijn beperkingen. Zo
worden voor de meeste landen enkel
de ervaringen in de belangrijkste stad
meegenomen, en in grote landen als
India twee steden: Delhi en Mumbai.
Volgend jaar komen daar nog acht
steden bij. Daarbij, zo schreven
onderzoekers Matthew Lillehaugen en
Milan Vaishnav in de zakenkrant Mint,
is de index een momentopname. 'Er is
een groot verschil met de reële
ervaring van bedrijven in de meeste
landen', aldus de twee, 'vooral waar de
informele economie bloeit en regels
slecht worden gehandhaafd.'

6
Government’smajorflagshipprogrammes
05 03
02
01
04
06
Make in India
Aimed towards
transforming India into a
global design and
manufacturing hub; till
February 2016,
Investment proposals
worth USD 223.9 billion
were received
Digital India
Provides digital
infrastructure and
governance
services to all
citizens
Skill India
A campaign aimed towards
skilling over 400 million
people in India in different
skills by 2022
Financial inclusion
As of November 2016, 255 million bank
accounts opened, ensuring access to
various financial services to the
underprivileged and provide an impetus
to the Direct Benefit Transfer scheme
Start-up India
A 19-point action
plan to promote
entrepreneurship
and develop a
holistic ecosystem
Smart cities
Around USD 7 billion have
been earmarked for 500
cities to improve the
quality of life by enabling
local area development
and Technology
implementation

7
CollectivelypropellingIndiatobecomethethirdlargesteconomyinthenext
decade(2016:number7intheworld–WorldEconomicForum)
730
million internet
subscribers
USD228
billion e-commerce
market
USD500
billion digital
payments market
583
million urban
population
USD7.5
trillion
contribution of
urban GDP
77cities,
population >1 million
23%
global middle class
from India
USD10,073
Indian median income
USD850
billion retail market
`

8
SpecificSectorAnnouncements
• Promote electronic
manufacturing in India
• Increased emphasis on
cybersecurity
• Promote digital
education in the country
• Higher credit target
for agriculture
• Focus on irrigation
and crop insurance
• Focus on ensuring
better prices for
agricultural
commodities
• Amend rules to
make drugs
available at
reasonable
prices
• Further liberalize
Foreign
investment
policy
Technology Agriculture Life Sciences

9
SpecificSectorAnnouncements
• Single window
clearance
• Phasing out of Foreign
Investment Promotion
Board (FIPB)
• Boost to digital
payments
• Plan to build 100
India-International
Skill Centres
• Smartcards
containing health
information to be
introduced
• Steps to promote
digital payments at
hospitals
• Reduce prices of
medical devices
Financial services Industrial manufacturing Healthcare

11
TaxandRegulatoryFramework
Direct Tax
• Direct taxes (Income tax) regulated by the Income-tax department.
Indirect Tax
• Indirect taxes regulated by the respective Indirect tax department.
Compliance
• Reserve Bank of India: Regulator of Indian Foreign exchange regulations;
• Registrar of companies: Authority regulating companies having presence in India;
• Social security: Social security compliances in India;
• Expat Services: Expat entry and exit formalities and compliances.

12
DirectTax-Structure
*Applicable Surcharge (2 % to 12 %) and Cess @ 3% on the above
Dividend
Distribution
Tax
Corporate
income-tax
Capital
Gains
Buy-back tax
Minimum
Alternate
Tax/ AMT
Tax treaty
• Tax on book profits as
computed under
Income-tax laws
• Rate: 18.5%
• Tax on taxable income as
per Income tax law
• Domestic Company -
30%
• Specified Company -
25%
• Foreign Company - 40%
• Tax on transfer of capital
asset (Land, Building,
Shares, securities etc.)
• Long term - 20%
• Short term - 30%
• Tax on buy-back of
shares
• Rate - 20%
• Tax on distributable
profits
• Rate - 15% (gross up
basis)
• Exempt from tax in
the hands of the
shareholder
• Robust tax treaty network
• Beneficial tax position may
be adopted for payments
like royalty, fees for
technical services, interest
etc.

13
IndirectTax-Structure
Federal system
• GST is a tax on consumption;
• Regular GST system: paid GST results in a credit and charged GST is payable to the
authorities.
Structure
• There is Integrated GST, Central GST and State GST; all are filed in the portal;
• This determines if the state or the federal government obtains the GST;
• This can affect the offset of GST input tax credits. For example State GST cannot be offset
against Central GST.
• The GSP portal is used for GST registration, filing GST returns and maintaining all GST
details;
• Entirely digital system with real time error detection;
• General rule: Taxpayers need to register in every state in which they have an aggregate
turnover of over approx EUR 25,000 (or 12,500 in some less developed states). Foreign
companies may need to register for incidental transactions.
Compliance

14
IndirectTax–SupplyofGoodsandServices
Taxable supply of goods
- A supply of goods is any supply that is not a service;
- Any transfer of title of goods;
- Goods can be subject to 7 different rates;
- The ‘place of business’ and ‘place of the supply’ are important to determine where tax is
due,
Taxable supply of service
• Anything other than goods, money and securities;
• Services can be subject to 5 different rates;
• The ‘place of business’ and the ‘location of the customer’ are important to determine where
tax is due,
General
- Invoices need to adhere to certain standards and should include among other things Name,
address and identification number of the supplier, charged GST, date etc.

15
IndirectTax–GSTbasicrules
Goods
• General rule: with transported goods the place of delivery is where termination of the
delivery takes place;
• Special rules exist for, among others, installed goods, goods sold on means of
transportation, goods which are not transported and mail order arrangements.
Services
• General rule (B2C): Physical location of performance of the service;
• Exceptions exist for when there is no physical location, then it often depends on the known
location of the receiving party;
• General rule (B2B): Location of the receiving party;
• Holds for almost all transactions as long as the receiving party is registered.

16
IndirectTax–GSTRates
Standard rates
• 5% applies to “goods consumed by ordinary people” and mostly transport services;
• 12% applies to more expensive food, such as meat, cheese, nuts and for example
restaurant without air conditioning, heating or liquor license;
• 18% applies to for example hotels with air conditioning and the default rate for any goods
not captured under other rates (for instance manufacturing).
Reduced rates
• 3% applies for instance to jewelry trade (to protect sector).
• 28% applies to Luxury Items; for example coffee, chocolate, chewing gum, soaps,
shampoos, car tires and ‘sin’ items such as tobacco, cigars.
Increased rates
• 1) Export goods (taking goods out of India) and services (recipient outside India), 2) export
to Special Economic Zone, 3) some cases interstate supplies.
Zero rate

17
IndirectTax–Integrated,CentralorStateGST
Place of
delivery
Place of
business
State A State A
Place of
delivery
Place of
business
State A State B
Place of
business
& delivery
Outside India India
Central GST and State GST
Integrated GST
Basic Customs duty and integrated
GST
Intra-state
Import
Inter-state

3.PossibleSalesPresencesinIndia

19
Sectorregulation
 Single brand retailing(b) 100%
 Multi brand retailing 51%
 Banking (Private Sector)(b) 74%
 Existing Airports 100%
 Telecom Sector (b) 100%
 Broadcasting 100%
 Print Media 26%
 Manufacturing sector
 Consulting services
 Insurance (49% cap)(a)
 Real Estate(a)
 E-commerce activities
 IT/ ITes
Government/ Approval RouteAutomatic Route
Prior approval from prescribed Competent
Authority/ DIPP
No prior approval, only post facto filings to RBI,
through Authorised Dealer
 
(a) Sector specific regulations to be complied with (b) Approval required where FDI is beyond 49 per cent
Prohibited
sectors
 Lottery, betting and gambling
 Manufacture of cigars, cigarettes, etc.
 Atomic energy, railway operations


20
LevelsofSalesPresence
Agent/ Sales Rep
No inventory ownership
Invoice in name of principal
No receivable, inventory, market risk
No Inventory, AR on B/S
P&L shows commission
Commissionaire
No inventory ownership
Invoice in name of commissionaire
Low risks
No Inventory, AR on B/S
P&L shows commission
Limited Risk Distributor
“Flash” inventory ownership
Invoice in name of LRD
Limited risks
No Inventory on B/S
P&L shows sales and COGS
Full Fledged Distributor
Inventory ownership
Invoice in name of FFD
Full risks
Full P&L and balance sheet
Sales Concepts
Full risk
Minimal risk very low
high
Responsibility Profile & Profits Level

21
Repoffice/Marketingagent
• Direct Tax implications
• Regulatory/compliance
• Indirect Tax implications
• In principle no taxable presence for direct tax purposes – always to be confirmed
locally!
• Important not to have representative office soliciting orders or negotiating contract on
behalf of the head office.
• Limited registration – always to be confirmed locally!
• Obtain approval from Reserve Bank of India – as per the FDI policies per industry of the
RBI.
• Register with the Registrar of Companies.
• In principle no taxable presence for direct tax purposes – always to be confirmed
locally!

22
SalesAgent/Commisionaire
• Taxable presence in India which might constitute a fixed place of business – always to
be confirmed locally!
• Even without a fixed place of business Indian source income will be taxed.
• Obtain approval from Reserve Bank of India – as per the FDI policies per industry of the
RBI.
• Register with the Registrar of Companies.
• Taxable presence in India which might constitute a fixed place of business – always to
be confirmed locally!
• Even without a fixed place of business one-off transaction into India might require GST
registration

23
WhatConstitutesabranch(directtax)
Business Income of a Dutch company is taxable in India only if a Dutch company has a “branch” in India.
Both options below may constitute a branch (so called permanent establishment (“PE”) for tax purposes)
• Fixed Place PE refers to a fixed place of
business through which business of an
enterprise is wholly or partly carried on
• Following ’Basic Rule’ tests shall be
cumulatively satisfied to determine
whether foreign company constitutes a
PE in India:
− Place of Business Test
− Business Activity Test
− Right to use/ Disposal Test
Fixed Place Permanent Establishment Agency Permanent Establishment
• Agency PE refers to an agent which
constitutes a fixed place of business of
an enterprise (its client/commissioning
company)
• A person who acts on behalf of a non-
resident and has and habitually exercises
in India an authority to conclude
contracts on behalf of such non-resident
‘client / commissioning company’.

24
SalesAgent/commissionaire(directtax)
Not having a PE in India Having a PE in India
Income-tax
Return (ITR)
To be filed within prescribed time limit,
if there are India sourced transactions
To be filed within prescribed time
limit for transactions of PE
Applicable if transactions are with
associated enterprises
To be undertaken within prescribed
time limit
Not required to be undertaken
To be undertaken if the turnover
exceeds USD 0.15 million (approx.)
Not required Advisable to maintain
On payments taxable in India, taxes
are required to be withheld
On payments taxable in India, taxes
are required to be withheld
Transfer
Pricing (TP)
Tax audit
Books of
accounts
Withholding
tax
• Up to 200% of tax
payable: Under
reporting/ Misreporting
• USD 1,500 (approx.)
• 2% of value of
transaction
• Not applicable
• Not applicable
• Interest @1% per
month
• Penalty equal to
withholding tax
• Expense disallowance
• Upto 200% of tax payable:
Under reporting/
Misreporting
• USD 1,500 (approx.)
• 2% of value of
transaction
• 0.5% of turnover or
USD 2,300 (approx.),
whichever is less
• Ad-hoc attribution of
revenues
• Interest @1% per month
• Penalty equal to
withholding tax
• Expense disallowance
Penalty for non-
compliance Compliances
Penalty for non-
compliance
Note: always check compliance requirements locally!

25
SalesAgent/Commissionaire(digitaleconomy)
Following the BEPS Action Plan 1, wherein imposition of Equalization Levy (EL) was recommended as an option to
mitigate challenges in taxation of digital transactions, the Indian government, vide Finance Act 2016 introduced EL
• Wef 1 June 2016, EL applicable on following ‘specified services’
– Online advertisement
– Provision for digital advertising space
– Facility or service for purpose of online advertisement
– Service as may be notified
• Applicable to residents and PE of NR, wherein 6% levy to be deducted
from payment to NRs
• Income subject to EL shall be exempt from tax in the hands of NR
service provider
Key Features
• NR has PE in India and ‘specified services’ effectively connected to
such PE
• Annual payment to NR for ‘specified services’ less than USD 1,500
(approx.)
• EL applicable only on B2B transactions
Exceptions
Whether
consideration is
subject to EL?
• Resident/ NR having PE to
deposit EL
• Consideration to NR - Tax
exempt
• No tax compliances required
by NR
• Taxes to be withheld and
deposited by resident/ NR
having PE as per contractual
arrangement
Is transaction
taxable as
royalty/ FTS?
No taxes to be
withheld by
resident/ NR
having PE
Yes
No
Yes
• Corporate tax return and
Transfer Pricing compliances
by NR?
No
Interplay between EL and
income taxability
Non-Resident
(NR)
Resident/ NR
having PE
Payment less
6% EL
Specified
Services
Overseas
India

26
Whatconstitutesabranchforindirecttax
Business Income of a Dutch company is taxable in India only if a Dutch company has a branch in India.
A Branch office for GST purposes is assumed earlier than for Corporate Income Tax Purposes
Fixed place of business Are you liable to GST even without a branch?
• For GST purposes, it must be a place of
sufficient substance only for the
purposes of supplying and receiving
services
• Subject to meeting the turnover criteria
for registration, a business is required to
register in every state “from where a
taxable supply is made”
• For CGST and IGST purposes, a place
which is characterized by a sufficient
degree of performance and suitable
structure in terms of human and
technical resources to supply services, or
to receive and use services for its own
needs.
• Subject to meeting the turnover criteria
for registration, a business is required to
register in every state “from where a
taxable supply is made”
• No necessary relationship between a fixed establishment for the purpose of direct tax and for
Indian GST.
• For GST purposes, it must be a place of sufficient substance only for the purposes of
supplying and receiving services.
• A branch means registration for GST! It should be a single registration in a State but not
several registrations in different states also possible.

27
Entity–LimitedLiabilityCompany
• Incentives
• Fully liable to direct taxes.
• Must comply with all
regulatory and compliance
matters.
• Fully liable to GST.
• Access to incentives.

28
ComparisonofLLCcomparedtootherentityforms
Unincorporated
Entities
Branch
Office
Liaison
Office
Project
Office
Incorporated
Entities
Joint
Venture
Wholly
Owned
Subsidiary
Unlimited
Partnership
Limited
Liability
Partnership
Partnerships
GOVERNING
INSTRUMEN
T
POST-
CONVERSION
FEATURES
• Perpetual
succession
• Limited liability
• Sectors
where FDI is
100% under
Automatic
Route
• Minimum 2
Partners with
2 Designated
Partners (1 to
be resident)
• LLP Agreement
• Tax neutral
conversion
possible
• Converted
company gets
dissolved
LLP is a tax efficient and
simple form of establishing
presence in India…
Tax neutral conversion of a company into
LLP possible, subject to satisfaction of
conditions
Key benefits
DDT not payable
No need to hold
Board meetings
Deemed Dividend
provisions do not
apply
CSR provisions not
applicable
Lesser compliances
Operational flexibility

30
IncentivesbyStateGovernment
• Fiscal incentives
• Capital Subsidy on fixed capital
• Indirect taxes Abatement
• Land price concession
• Power tariff subsidy
• Stamp Duty Exemption
• Electricity Duty Exemption
• Plus, a host of other benefits…
• Non-fiscal incentives
• Relaxation under labour laws
• Single window clearance
• Skill Development
• Investor Facilitation
• Investor After Care Cell
Special fiscal incentives available on a case to case basis based on the scale of the
project and its contribution to the development of the state and its people
Competitive federalism and ranking of States basis the ease of doing business, this has
encouraged the State governments to provide incentives for setting up companies which
would lead to development of the States

31
KeyIncentives
1
Agricultural
extension project
2
Skill development
project
3
Purchase of plant
and machinery
4
Research and
Development
Tax holidays5
• Weighted average deduction of 150% on expenditure incurred on notified
projects
• Weighted average deduction of 150% on expenditure incurred on notified
projects
• Additional depreciation of 20% on purchase of plant and
machinery for the business of manufacturing or production
• Weighted average deduction of 150% on expenditure
incurred on scientific research carried out in approved in-
house R&D facility
• Profits of start-ups exempted for 3 consecutive years from
the year of incorporation
• Profits from housing projects exempted
M-SIPS6
• Financial incentives for electronic manufacturing companies
under Modified Special Incentive Package Scheme
Note: key incentives are updated regularly – always check locally!

5.TaxandRegulatory
RecentUpdates

33
PlaceofEffectiveManagement
Final Guidelines issued on 24 January 2017
• New Rule based on decision-
makers’ location applicable from
FY 2016-17.
• Intent to target shell companies
created for retaining income
outside India.
• POEM = Place where key
management and commercial
decisions necessary for conduct of
business as a whole are, in
substance made.
• Potential implications - Global
income taxable in India, mandatory
India tax compliances.
NEW RESIDENCE
RULE
India
Outside India
POEM
in India?
I Co.
F Co.

34
GeneralAnti-AvoidanceRules(GAAR)
GAAR is an anti-avoidance rule introduced with the objective to deny tax benefits under the impermissible avoidance
arrangements
Applicable to arrangements entered on or after 1 April 2017
Investments made before 1 April 2017 grandfathered
If a tax avoidance strategy addressed by the Limitation of
Benefits clause in the tax treaty, GAAR may not be invoked
Threshold of tax benefits of INR 30 million (approx. EUR
400,000) prescribed for invoking GAAR provisions
Impact of GAAR to be considered for future business arrangements
Key Points to be
considered

35
InvitingForeignInvestorCommunity
Boost Foreign Investment
• Foreign Portfolio Investors exempt from indirect transfer taxation of shares
• Beneficial withholding tax rate @ 5% on Rupee denominated bonds extended to 2020
• Transfer of Rupee Denominated Bonds between two non-residents exempt from tax
Start-up India
• Conditions for 100% tax holiday claim relaxed – to be checked locally
Corporate tax rate
• 25% for domestic companies having turnover not exceeding INR 500 million in financial year
2015-16

36
TaxauditandLitigationTrend
The tax authorities are closely monitoring the transactions with the foreign entities and trying to bring
such transactions to tax, thereby, necessitating the need to relook the current transaction structures
• Sale of copyright or copyrighted article
• Whether right of reverse engineering, disassembling and
reverse compiling granted?
• Whether right to make copies for further exploitation
granted?
• LO shall not be involved in soliciting orders or
negotiating terms of contracts
• Mere signing of contract outside India does not itself
mean that contracts were concluded outside India
• Employees of LO shall not be paid sales linked
incentives
Taxability of offshore supplies
• Separate agreement shall be entered into for supply and
services
• Payment for supplies shall not be linked with the
performance of services
• Risk and title of goods shall be transferred outside India
Taxability under secondment arrangements
• No lien on the employment with F Co.
• Secondees shall work under the supervision and control
of I Co.
• Where possible, salary to employees shall be directly
paid by the I Co.
Taxability of fees for technical services
• Whether human element is involved in rendering the
services?
• Whether ‘make available’ condition is satisfied?
• Whether benefit of ‘MFN clause’ can be obtained?
Taxability of sale of software
Constitution of Liaison Office as PE

6.KPMG’sRoleinIndia
IndiaTeamCV’s

and is a member of KPMG International Cooperative ("KPMG International"), a Swiss entity. All rights reserved. 38
KPMGisprivilegedtobepartofallnationalandkeystateprograms
INDIA
FIRST
Make in India
Swacch Bharat
Ease of Doing
Business
Start Up India
Digital India
Smart Cities
Skill India
For us it is
always
Managing the PMC by
•Working closely with 21 Ministries
across 22 key sectors
•Monitoring and reporting progress
•Validating Outcomes
•Developing web based reporting
dashboard
•Suggesting further areas for inclusion
•Citizen
engagement
•Technology
selection
•Policy Review
•Performance
measurement/Assessment
•Data collection, analysis
•Policy and Guideline
preparation
•Monitoring of the work of the
Training partners
•Technology enablement
• Policy Review
• Monitoring and Evaluation
• Best Practices Study &
Recommendation
•Investment
Promotion
•Smart Urban
Planning
•Financial Modeling
•Capacity Building
• Issuance of
Guidelines
•Single Window System
•Common Application Forms
•Departmental reforms

39
© 2017 Meijburg & Co M&A Tax B.V. has its seat at Amsterdam, the Netherlands, is registered under Chamber of Commerce registration number 34154136 and is affiliated
with KPMG International Cooperative ("KPMG International"), a Swiss entity. All rights reserved.
CV–CeesvanderHelm
Name Cees van der Helm
Position Tax Partner, Meijburg & Co, Amstelveen, the Netherlands
Global Japanese Practice Member / EMEA Japanese Business Steering Committee Member
Qualifications - MA Tax Law, University of Tilburg
- MA Business Finance, University of Tilburg
- Post-Academic European Tax, University of Rotterdam
- Member of the Dutch Association of Tax Advisers
- Member International Double Taxation Knowledge Group – KPMG/Meijburg & Co
- Chairman Leasing Taxation Knowledge Group – KPMG/Meijburg & Co
Experience Cees is based at KPMG/Meijburg & Co’s Amstelveen office, with a focus on Asian based clients. He is the
Dutch coordinator for the Japan Desk for KPMG in which capacity he coordinates the services to the
Japanese clients of KPMG in the Netherlands. Cees consults his clients on implementing international tax
structures, including M&A, cash management, financing and holding structures. He is a regular speaker on
seminars on Dutch and international taxation for the Japanese business community in the Netherlands. Cees
travels quarterly in the Asian region to meet with his clients. Cees is fluent in Dutch and English with a basic
understanding of German.
Cees co-ordinates a wide range of tax services from corporate income tax to custom duties and VAT. Cees
serves as tax advisor to a large number of Asian corporations that have set up their holding and finance
companies in the Netherlands.
Sector
experience
- Mergers & Acquisitions
- Chemicals and Logistics
- Asia
- Corporate income tax
Cees van der Helm
Partner
KPMG Meijburg & Co
M:+31 6 2120 1009
D: +31 (0) 88 909 1577
VanderHelm.Cees@kpmg.com

40
© 2017 Meijburg & Co M&A Tax B.V. has its seat at Amsterdam, the Netherlands, is registered under Chamber of Commerce registration number 34154136 and is affiliated
with KPMG International Cooperative ("KPMG International"), a Swiss entity. All rights reserved.
CV–MohamedArichi
Name Mohamed Arichi
Position Senior Tax Manager, Meijburg & Co, Amstelveen, the Netherlands
Qualifications - Mohamed Arichi is an International Tax Lawyer and holds membership of the Dutch Association of Tax
Advisors;
- Master’s in Tax Law, University of Amsterdam;
- Master’s in Civil Law (summa cum laude), Vrije Universiteit, Amsterdam;
- Master’s in Criminal Law (summa cum laude), Vrije Universiteit, Amsterdam;
- Previous board member of the Procedural Law Chapter within the Dutch Association of Tax Advisors.
Experience Mohamed has extensive international experience, including working in the Middle East region for KPMG
Qatar. He is involved in advising clients located in Asia and the Middle East.
Mohamed has experience in advising international clients on different tax aspects, M&A transactions and
(post-acquisition) restructurings. Mohamed assisted in coordinating services in respect of specialist areas,
such as transfer pricing, VAT, customs duties and payroll tax.
Mohamed’s client portfolio consists of companies active in various sectors, such as the Power Energy, ENR,
Telecommunication, FinTech and Pharmaceuticals.
Mohamed has experience in national and international procedural law. Mohamed assisted with tax reforms,
e.g. tax policy design, setting up of tax authorities.
Specializations in the following areas:
• International Tax;
• Corporate Income Tax;
• Dividend withholding tax;
• European tax law;
• Tax planning and structuring;
• Mergers and Acquisitions.
Mohamed Arichi
Senior Tax Manager
KPMG Meijburg & Co
M:+31 6 1537 2628
D: +31 (0) 88 909 1053
Arichi.Mohamed@kpmg.com

All activities performed and all services rendered by Meijburg & Co are
subject to its general terms and conditions, filed with the Dutch
Chamber of Commerce.
Meijburg & Co, Tax Lawyers, is an association of limited liability
companies under Dutch law, registered under Chamber of Commerce
registration number 53753348 and is a member of KPMG International
Cooperative ("KPMG International"), a Swiss entity.
The general terms and conditions are available on the Meijburg & Co
website (http://www.meijburg.com/termsandconditions) and will be
supplied upon request.

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