Dutch district court again allows 25 % tax sparing credit on Brazilian interest on net equity At the end of last year (on 8 December 2023) a Dutch district court (the “Court”) ruled again that “interest on net equity” (“IoNE”)…
We would like to inform you of an important development regarding the reporting requirement for work-related personal mobility, which will come into effect on July 1, 2024. This is not a tax regulation, but rather a regulation related to the…
This Budget Day Special from Atlas Tax Lawyers outlines important proposals in the Dutch 2024 Tax Plan and additional bills for you. The special is divided into the following topics: Please click here to see our Budget Day Special 2024.
Brazilian taxpayers need to comply with new OECD-based transfer pricing rules as of financial years starting on or after 1 January 2024. They are also allowed to apply the new rules for financial years starting on or after 1 January…
On 6 July 2023, the Dutch House of Representatives passed legislation to implement public country-by-country reporting under EU directive (EU) 2021 In-scope multinational enterprises (MNEs) are required to publicly disclose a country-by-country report (CbCR), which includes tax and tax-related information.…
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 Belgian personal holding companies (we also refer to our Newsflash…
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”). With the Law, Brazil’s transfer pricing (“TP”) rules are aligned…
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 of 25 % in relation to the “interest on net…
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 published documents on simplification regulations (so-called “Safe Harbours”) on tax…
We are delighted to announce that Atlas Tax Lawyers has appointed Taco Wiertsema as Partner and Yvonne Bakker as Counsel, as of January 1st, 2023. Taco is a member of our Transfer Pricing team, as Counsel, since 2020. He is…
Frederik Mulder en Matthijs Wierenga zijn dit jaar allebei genomineerd voor Best M&A Tax Advisor! Wij zijn supertrots op Frederik en Matthijs, het Atlas M&A team en de fantastische deals die deze nominaties mogelijk hebben gemaakt! Onze felicitaties gaan natuurlijk…
On 8 November 2022, the Court of Justice of the European Union (CJEU) issued a long-awaited (landmark) decision in the Fiat-Chrysler state aid case. The CJEU set aside the judgement of the General Court of the European Union. It annulled…
