Part of Svalner Atlas Group
Atlas Welcomes Frederik Mulder to the partner team We are proud to announce that Frederik Mulder has been appointed as partner in our M&A team. Frederik, who joined Atlas in 2012, is specialized in setting up management incentive programs and…
On 9 October 2019, the OECD published a proposal for a “unified approach” to the nexus and profit allocation challenges arising from the digital economy. Background The proposal combines elements of three competing proposals from several OECD member countries and…
Atlas is very proud to announce that, after years of hard work, it is ranked by International Tax Review as Tier 2 firm in the 2020 edition of World Tax, the comprehensive guide to the world’s leading tax firms. We’re very…
In line with previous proposals, the Dutch Ministry of Finance announced to introduce a conditional withholding tax on interest and royalty payments as of 2021. Under the new Withholding Tax Act 2021 (“WHTA” ) a withholding tax will be levied…
The third and final article on the use of credit ratings by transfer pricing practitioners and tax authorities, in the mini-series by Joris Steunenberg and Mick Willemsen, has been published on Transfer Pricing Week (“TP Week”). The third article provides…
The second article on the use of credit ratings by transfer pricing practitioners and tax authorities, in the mini-series by Joris Steunenberg and Mick Willemsen, has been published on Transfer Pricing Week (“TP Week”). The second article provides a framework…
Atlas is very proud to be recognized by the market as Tier 2 in the 2019 Tax Advisory Survey of the International Tax Review. The survey is carried out among ITR’s global readers including global tax directors, who were asked…
Joris Steunenberg and Mick Willemsen have written three technical articles on the use of credit ratings by transfer pricing practitioners and tax authorities, which are published on TP Week in the coming weeks as a mini-series. The technical articles concern…
On 2 July 2019, the legislative proposal to implement the provisions of the EU Anti-Tax Avoidance Directive 2 (ATAD2) was submitted to the Dutch parliament. ATAD 2 combats both hybrid mismatches among EU Member States and between EU Member States…
On 28 June 2019, the State secretary of Finance published a decree on the revised ruling policy for rulings with an international character (hereinafter: international rulings). This decree replaces three previous decrees on the ruling policy (dated 3 June 2014)…
Recent heeft het Hof Van Justitie van de EU geoordeeld dat een commissaris, ondanks dat de toezichthoudende activiteiten gezien kan worden als een economische activiteit, geen btw ondernemer is. Dit oordeel heeft in veel gevallen een impact op de btw…
On 26 February 2019, the Court of Justice of the European Union (CJEU) took a decision in the so-called “Beneficial Ownership Cases”, concerning the application of the Interest and Royalty Directive (IRD) and the Parent-/Subsidiary Directive (PSD). In the decisions, the CJEU ruled that Member States must deny the benefits granted under the two Directives in case of an abusive situation. In response of this CJEU ruling, members of the Dutch parliament raised several questions to the Ministry of Finance on the interpretation of the rulings and the Dutch reading of ‘abusive structures’. In a letter of 14 June 2019, the Dutch State Secretary of Finance addressed the questions.
