Part of Svalner Atlas Group
Part of Svalner Atlas Group
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…
On October 24, 2022, the Netherlands published the draft bill on Pillar Two called ‘Minimum Tax Rate Act 2024’. This draft bill is open for public consultation until December 5, 2022. Although a bit later than anticipated, the Netherlands is…
This Budget Day Special from Atlas Tax Lawyers outlines important proposals in the Dutch 2023 Tax Plan and additional legislative proposals. The special is divided into the following topics: » measures for companies; » measures for employers; » measures for…
We are delighted to announce that Atlas Tax Lawyers N.V. (Atlas) has appointed Gerben Markink as a Partner Indirect Tax as of September 1st, 2022. Since 2013, he is a member of our team in the role of of-counsel. Gerben…
Interested in the outcome of the Amsterdam Court of Appeal on a distribution to a Belgian family holding company? Our colleagues, Dennis Kamps, Steven Vijverberg and Ivo Kuipers have written a newsflash that may be relevant to all foreign personal…
Today, the Dutch State Secretary of Finance published an update of the 2018 Transfer Pricing Decree (in Dutch). The 2022 Decree provides the further details on the application of the arm’s length principle from the Dutch Tax Authorities’ perspective. Most…