Part of Svalner Atlas Group
Part of Svalner Atlas Group
On 10 January 2019, the European Commission (“EC”) opened a formal State aid investigation into tax rulings granted by the Dutch tax authorities (“DTA”) to two Nike group companies, European Operations Netherlands BV and Converse Netherlands BV (“DutchCo’s”). The EC…
The Netherlands has unilaterally published a list of low-taxed jurisdictions. This list will have an impact on the application of the newly introduced CFC rules, on the proposed withholding tax on intra-group interest and royalties payments and on the possibility…
Qualification of an early termination payment for the purposes of VAT The CJEU has decided that an early termination payment made by a client to a telecom service provider must be viewed as remuneration for a VAT taxed service, rather…
We warmly welcome Boudewijn Niels among our partner team, taking effect on 1 January 2019. Boudewijn is specialized in tax aspects of private equity and M&A transactions. Additionally, he has broad experience in advising on the tax structuring of (cross-border)…
Last week, on 22 November 2018, the State Secretary of Finance published a letter in which he described the contemplated changes to the current tax ruling practice. According to the Ministry of Finance, the purposes of the changes is to…
On 29 October 2018, the Dutch Government published a consultation document regarding the implementation of the Anti-Tax Avoidance Directive measures (“ATAD 2”) as adopted by the EU in May 2017. The consultation document is open for consultation until 10 December 2018.
ATAD 2 should be implemented by the EU Member States on 31 December 2019. However, the rule targeting reverse hybrid mismatches need to be implemented on 31 December 2021. The implementation by the Netherlands of ATAD2 is in line with this timing.
On 17 October 2018 the Court of Justice of the European Union (‘CJEU’) rendered its decision in the Ryanair case (C-249/17). This decision handles the issue of input VAT recovery for costs in connection with unsuccessful share deals (broken-deal costs). Below we will highlight the importance of this decision for practice, more in particular Private Equity and M&A in general.
On Budget Day (18 September 2018), the new tax measures for 2019 and further were published. Earlier this week, on 15 October 2018, the Dutch government announced that its initial budget proposals will already partially be revised. After heavy debates…
Op Prinsjesdag, dinsdag 18 september 2018, heeft het kabinet het Belastingplan 2019 aangeboden aan de Tweede Kamer. Wij hebben een nieuwsbrief opgesteld waarin wij de belangrijkste maatregelen voor Private Clients op een rij hebben gezet. Om onze nieuwsbrief te bekijken, klik hier.
On Budget Day (18 September 2018), the Dutch government published the new tax measures for 2019 and beyond. The package also includes the long-awaited proposals for the implementation of ATAD1, such as the earnings stripping rules and CFC. Other highlights…
On Budget Day 2018, the Dutch government released its much debated proposal to abolish the dividend withholding tax of 15% as of 2020. Instead of the current provisions, a new specific withholding tax will be introduced for abusive situations. Proposal…
On Budget Day, the Dutch government submitted a legislative proposal regarding the implementation of the Anti-Tax Avoidance Directive as agreed mid 2016 by the EU member states (“ATAD1”). The most important measures are the earnings stripping rules that limit the…