Part of Svalner Atlas Group
On 16 February 2024, the Dutch Supreme Court ruled that entering into a marriage contract at or during the marriage does not result in a (taxable) gift. This is also the case if spouses are entitled to unequal shares of…
On 1 January 2025, new legal entity and partnership classification rules will enter into force. The Dutch Ministry of Finance now published a draft decree (Decree) that provides further guidance on these rules. This is highly relevant because based on…
Under the Tax Plan for 2024, the 30% ruling is scaled back as of the 1st of January 2024. The benefit of the 30% ruling will gradually decrease over its five-year term, transitioning ultimately into a 10% ruling. More precisely,…
We are pleased to announce that Atlas welcomes Arthur Smeijer as counsel in the Corporate M&A team effective January 15, 2024. Over the past 10 years Arthur has specialized in international tax matters related to the real estate market. Arthur…
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…
