Approach to tax

Numidia’s strategy for the group taxation structure is "tax follows the business," meaning that the optimal business structure prevails over the optimal tax structure. The BoD evaluates the tax strategy on an annual basis.

The goals of this strategy are as follows:

  • facilitate the optimal business structure

  • be compliant with all applicable legislation

  • ensure that all stakeholders receive a fair share of tax income

  • avoid the risk of tax evasion

Corporate income tax and transfer pricing

The Numidia group operates in five jurisdictions with respect to corporate income tax:

  • The Netherlands (all Dutch entities form a fiscal unity for corporate income tax purposes)

  • Singapore

  • United States

  • Uruguay

  • Australia

Because we operate on a global scale, we follow the OECD guidelines for transfer pricing. We have taken the following steps to determine our transfer pricing strategy:

  • An independent tax advisory firm has been engaged to set up the right structure and ensure compliance with all OECD and local tax requirements.

  • The OECD arm’s length standard and methods for testing the arm’s length nature of intercompany transactions have been evaluated. The OECD guidelines do not prescribe a strict hierarchy of applicable methods. They do, however, require that the selected method provide the best estimation of an "arm's length" price.

  • A benchmark study has been conducted to determine the estimation applied.

  • Master files, local files and country-by-country reporting have been set up for all applicable countries in line with the requirements. These files are available at Numida’s headquarters upon request of tax authorities and taxation stakeholders.

As a result, we are confident that we meet all applicable tax legislation:

  • OECD Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations published in July 1995 and subsequently updated in 1996, 1997, 2010, 2017 and 2022.

  • Dutch legislation: Article 29G of the Dutch Corporate Income Tax Act and the Dutch transfer pricing decrees of 4 June 2022, no. IFZ 2022/16685 and 30 December 2015, no. DB/2015/462M.

  • Local Singapore, US and Uruguay requirements not covered by the OECD or Dutch guidelines.

Corporate income tax charges are accounted for on a monthly basis on both the local and consolidated levels through the use of accruals.

During 2022, we submitted CIT filings in all five jurisdictions within the required deadlines and within local standards and requirements. We engaged local tax advisory companies in all jurisdictions to support and prepare the filings.