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Passion for tax


Advocate-general opinions on the application of the Dutch dividend withholding tax exemption in 2 Belgian holding company cases

On June 9, 2023, Advocate-General Wattel (hereafter referred to as A-G) issued two opinions in cases concerning the application of the dividend withholding tax (DWT) exemption regarding dividend distributions to […]

New transfer pricing rules in Brazil: opportunities & risks

On 15 June 2023, the provisional measure n. 1152/22 – published on 29 December 2022 – was converted into law with the publishing of Federal Law n. 14.596/23 (the “Law”). […]

Dutch district court allows 25 % tax sparing credit on Brazilian interest on net equity

Earlier this month (on 1 May 2023), the Dutch district court in Breda (“Court”) decided that the Dutch taxpayer X BV has the right to apply a tax sparing credit […]

Webinar: Pillar Two – Deep Dive OECD Safe Harbours

When: February 8, 2023 Time: 4 – 5 pm On December 15, 2022, the EU directive on global minimum taxation (GloBE Rules or Pillar Two) was passed. The OECD subsequently […]


The ATAD general anti-avoidance rule in the Netherlands

The Dutch legislator decided not to implement the General Anti-Avoidance Rule (“GAAR”) of the EU Anti-Tax Avoidance Directive (“ATAD”) and to rely on the court developed fraus legis doctrine.    As there are several […]

Economic Analysis and Impact Assessment of the Pillar 1 & 2 Proposals

On 13 February 2020, the OECD published a (first) economic analysis / impact assessment of the (combined) Pillar 1 & 2 proposals). Background The OECD recently published the proposals for […]

OECD releases Transfer Pricing Guidance on Financial Transactions

On February 11, 2020 the OECD released the highly anticipated report “Transfer Pricing Guidance on Financial Transactions” (“the report”), which deals with the follow-up work in relation to Actions 8-10 […]

Abuse of Law under EU Directives – Derivatives & Financial Instruments, 2019 (Volume 21), No. 6

In this article the authors Frederik Mulder and Yves Cattel discuss the ruling of the European Court of Justice in the so-called “Danish cases” (T Danmark – Case C-116/16 and […]

are pragmatic and have international experience
highly technical in their area of expertise and prompt in responding to requests
Boudewijn is pleasant to work with, pragmatic and always available
Atlas provides valuable technical assistance in a timely fashion
The team is technically creative and adopts a commercial and practical approach to solving issues
Practical excellence. They know their stuff, but do not over complicate matters for the client. Small teams with partner involvement throughout the process.
Straightforward, sounding board, personal touch.
Boudewijn consistently brings key messages together and allows us to take commercial decisions quickly
It’s a different kind of advisory style, more hands-on, less of a paper trail to work through than with some larger firms.
They are knowledgeable with a proactive attitude
Lines are short and their knowledge of the tax function within a business exceeds the more theoretical big-four knowledge.
Boudewijn Niels enters the Chambers rankings this year reporting that he is “a pragmatic tax adviser with thorough knowledge and a pleasant approach towards clients and other advisers.”
The work is performed in accordance with high standards, often exceeding big-four standards.