Tax Lawyers / Fiscalisten

News

Proposal to amend the dividend withholding tax regime

On the third Tuesday of September 2017 (traditionally Budget Day in the Netherlands), the Ministry of Finance has proposed changes to the Dutch Dividend Withholding Tax Act and the foreign…
News

2018 Budget day: tax measures

On 19 September 2017, the Dutch Ministry of Finance published its tax budget proposals for fiscal year 2018 and future fiscal years. This article gives you an overview of the…
News

Prinsjesdagspecial - Fiscale maatregelen 2018

Op Prinsjesdag heeft het demissionaire kabinet de fiscale maatregelen voor 2018 bekendgemaakt. In deze Prinsjesdagspecial zetten wij de voorstellen voor u uiteen. Klik hier om deze te openen. 
News

Luxembourg introduces new IP tax regime

On 4 August, the Luxembourg Government submitted its long awaited bill of law for the introduction of a new tax regime in order to increase intellectual property (“IP”) developments (the…
Events
27 August - 1 September | Rio de Janeiro

IFA 2017

The International Fiscal Association's 71st congress takes place in Rio de Janeiro, Brasil. A joint delegation of Tiberghien, T/A economics and Atlas (working together via the T/A international platform) will be attending the congress. This…
News

Internet consultation on Dutch implementation proposal EU Anti-Tax Avoidance Directive

On 10 July 2017, the Dutch Government published a preliminary proposal for consultation to implement the Anti-Tax Avoidance Directive measures (ATAD1) as adopted by the EU in June 2016. The…
News

OECD releases latest updates to the Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations

On July 10, 2017 the OECD released the 2017 edition of the OECD Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations (Transfer Pricing Guidelines). The Transfer Pricing Guidelines provide…
News

OECD releases BEPS discussion drafts on attribution of profits to permanent establishments and transactional profit splits

OECD releases BEPS discussion drafts on attribution of profits to permanent establishments and transactional profit splits On June 22, 2017 the OECD released two public discussion drafts, containing guidance on…
News

Atlas continues to expand!

We have not lounged around since the announcement last year of our Benelux cooperation with the Belgium-Luxembourg lawfirm Tiberghien under the T/A international umbrella. Since the announcement, our transfer pricing and valuation…
News

Revision period for valuable services

Revision period for valuable services As early as 2005 a parliamentary bill has been submitted regarding the implementation of a revision period towards valuable services. This regulation should be an…
News

Preliminary proposal to amend the dividend withholding tax regime

The Dutch Deputy Minister of Finance published a preliminary tax proposal for consultation on 16 May  2017 with proposed changes to the Dutch Dividend Tax Act. These changes include a…
Events
May 11, 2017, Amsterdam

11 May 2017 | 15th Brazil Seminar

In its efforts to strengthen ties between Brazil and the Netherlands, Atlas’ Brazilian Desk is promoting with BRADUTCH (the Brazilian Dutch Chamber) the seminar “Agribusiness Locomotive for Brazil Trade Mission”…
Publications

VAT and Directors’ Fees in the Benelux

The VAT Directive does not clearly address the question of the VAT treatment of directors’ fees, and recent developments in Dutch, Belgian and Luxembourg VAT legislation have emphasized the lack…
News

Supreme Court clarifies abuse of law doctrine and counterevidence anti-base erosion rules

In April 2017, the Dutch Supreme Court issued four rulings in ten cases on tax planning structures set up by the international banking group Credit Suisse. The rulings of the…
News

Atlas assists argenx with Dutch tax agreement regarding business restructuring

A team of Atlas Tax Lawyers led by Matthijs Wierenga (tax partner) and Frank Schwarte (transfer pricing partner) has assisted the biotech company argenx reach an agreement with the Dutch…
News

Hybrid mismatches with third countries

On 21 February 2017, the EU Member States reached an agreement on the proposed amendments to the Anti-Tax Avoidance Directive (“ATAD”). One of objectives of this new Directive (“ATAD 2”)…
News

Initial position of the Netherlands on OECD BEPS Multilateral instrument

On 21 March 2017, the Dutch Ministry of Finance submitted a letter to Parliament confirming their views regarding the Multilateral Instrument (“MLI”). The position of the Netherlands is in line…
News

EJC ruled on application Parent-Subsidiary Directive for Dutch investment institution

Recently the European Court of Justice (“EJC”) ruled that a Dutch fiscal investment institution (Fiscale beleggingsinstelling or “FBI”) is not entitled to invoke the Parent-Subsidiary Directive (90/435/EEG) (“Directive”) as a…
News

Draft bill on implementation UBO register

On March 31, 2017 a draft bill on the implementation of the Ultimate Beneficial Owner (UBO) register was presented for public consultation. The bill results from the European Directive 2015/849…
News

30 March - 31 March 2017 | Indirect TAX Forum

Dirk Evers and Leonie de Rooij will be attending Indirect TAX Forum 2017 in Düsseldorf. Please find more information here and click here to download the brochure. We hope to…
Events

14 March - 17 March 2017 | MIPIM Cannes

Bas Leensma and Joël Wessels will be attending MIPIM in Cannes, France. We hope to see you there!
News

Updated Decree Participation Exemption released

A new Decree Participation Exemption (the “Decree”), dated 20 January 2017, has been released. The Decree describes further guidelines on the participation exemption regime and replaces the previous Decree of…
News

Atlas establishes a Brazilian Desk

Atlas Tax Lawyers is pleased to announce it has established a Brazilian Desk. The desk will be headed by both Brazilian tax lawyer Martha Formenti, new associate at Atlas, and…
News

Opinion Advocate General of Dutch Supreme Court on scope Dutch base erosion rules (article 10a CITA)

Recently the Advocate General (“AG”) rendered its opinion on the Dutch interest deduction limitation rule of article 10a CITA. According to the AG article 10a CITA is also applicable in…
News

Agreement on the proposed amendments to the Anti-Tax Avoidance Directive

On 21 February 2017, the Ecofin reached an agreement on the proposed amendments to the Anti-Tax Avoidance Directive (“ATAD”) which neutralizes the effects of hybrid mismatches between EU members states…
News

T/A economics: Painting a new story...

... as the BeNeLux alternative for transfer pricing and valuation services, yet with a distinct approach. Atlas and Tiberghien are pleased to announce the launch of T/A economics, a joint…
Publications

The post-BEPS advantages of the Netherlands

Roelof Gerritsen and Ivo Kuipers, both partners at Atlas Tax Lawyers in the Netherlands, look at why the country will remain a prime location for multinationals and foreign investors as…
News

Luxembourg introduces new rules applicable to intra-group financing companies – rules applicable as from 1 January 2017

1. IntroductionThe Luxembourg direct tax authorities issued on 27 December 2016 new guidelines by means of the issuance of Circular L.I.R. no. 56/1 – 56bis/1 (hereinafter the “Circular”) which deals…
News

New innovationbox regime in The Netherlands

NEW INNOVATIONBOX REGIME IN THE NETHERLANDS As announced earlier in 2016, the Netherlands has enacted a new innovation box regime as of January 1, 2017, in line with the outcomes…
News

We are proud to announce...

...A new partner: Kristel Tijsterman.
News

Dutch deemed salary rule under the application of double tax treaties

Dutch deemed salary rule under the application of double tax treaties The Dutch Supreme Court has recently decided that the Netherlands could not apply the domestic deemed salary rule under…
News

Further clarifications published on proposed amendments to Dutch dividend withholding tax act

Further clarifications published on proposed amendments to Dutch dividend withholding tax act In addition to our recent news alert in relation to the proposed amendments to the current Dutch dividend…
News

VAT treatment of unpaid invoices

VAT treatment of unpaid invoices VAT is due on the supply of VAT taxable services or goods. The supplier pays the VAT due to the Dutch Tax Authorities (‘DTA’) and…
News

Ecofin has not yet reached an agreement on the proposed amendment of the ATAD regarding Hybrid Mismatches with third countries

Ecofin has not yet reached an agreement on the proposed amendment of the ATAD regarding Hybrid Mismatches with third countries On 6 December 2016, the Ecofin did not come to…
News

Multilateral instrument to implement BEPS measures

Multilateral instrument to implement BEPS measures A group of more than 100 jurisdictions have agreed upon a multilateral instrument (“MLI”) for the implementation of certain tax treaty measures of the…
News

Dutch government responds on proposal ATAD and hybrid mismatches with third countries

The Dutch government responds on the amendments to the Anti-Tax Avoidance Directive (“ATAD”) proposed by the European Commission last month. The proposal in particular addresses the neutralisation of hybrid mismatches…
News

Netherlands postpones deadline for CbCR notification

On Monday November 21, 2016, the Dutch State Secretary of Finance announced he is postponing the deadline for the country-by-country-reporting notification. The first CbC-reports, covering FY2016, are not due until…
News

Leading Firms

Atlas is proud to announce that we will again be one of the leading companies in Tier 3 of the ITR this year.
News

IBA Conference: The New Era of Taxation

17 - 18 November 2016 | Koninklijke Industrieele Groote Club in Amsterdam   Ivo VANDE VELDE will participate in the panel discussion on Exit Taxation at the upcoming IBA Conference in…
Events

7 March - 10 March 2017 | TP Minds International London

Frank Schwarte and Andy Neuteleers will be attending TP Minds International in London.  We hope to see you there!
News

2017 Luxembourg Tax Reform | Draft law

On 26 July 2016 the Luxembourg Government submitted the draft law no. 7020 to the Luxembourg Parliament. The draft law includes a number of direct and indirect tax measures, most…
Events

25 September - 30 September 2016 | Madrid IFA Congress

Kristel Tijsterman, Jan Willem Lubbers and Ivo Kuipers will be attending the 70th IFA Congress in Madrid. Tiberghien will be there as well with a delegation from Belgium and Luxembourg.…
Events

17 November - 18 November 2016 | Amsterdam IBA Conference

IBA Conference: The New Era of Taxation: What You Need to Know in a Constantly Changing World. Both Atlas and Tiberghien will be attending this conference in Amsterdam. We hope…
News

Recent case law: interest deduction limitation to prevent base erosion

On 5 June 2016 and on 8 July 2016, the Dutch Supreme Court decided in two important cases on the rebuttal rules in the interest deduction limitation to prevent base…
News

The end of withholding tax on gross basis!: ECJ decision in Brisal Case

On July 13, 2016 the European Court of Justice rendered a milestone decision on withholding tax on interest payments within the EU (case C-18/15, Brisal – KBC Finance Ireland). The…
Publications

Dutch tax consequences “per element approach” Groupe Steria case

On 8 July, 2016, the Dutch Supreme Court has requested the ECJ to clarify whether the ‘per-element approach’ adopted by the ECJ in the Groupe Steria case is (and to…
Publications

Netherlands: The advantages of a Dutch holding company

In recent times, there has been increasing interest in the Netherlands from multinational companies that wish to avoid supposed tax havens and blacklisted jurisdictions. Roelof Gerritsen and Ivo Kuipers of…

Logo

Weteringschans 24 / 1017 SG Amsterdam
T +31 20 535 4567

info@atlas.tax


Member of

Follow us