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News
Negative wage income in case of share transfer triggered by bad leaver clause
On 14 April 2025, the Dutch Tax Authorities published a Knowledge Group opinion on the recognition of negative wage income due to the triggering of a bad leaver clause. The…
Amendment to tax treaty eases remote work rules cross-border workers the Netherlands & Germany
On April 14, 2025, the Netherlands and Germany announced an amendment to their tax treaty aimed at providing more flexibility for cross-border workers who work from home. This adjustment allows…
Performing valuations for taxation purposes; process, methods and certainty
Introduction Valuations play a crucial role in the realm of taxation, enabling tax authorities, companies and individuals to determine the value of a company, an asset or a liability. Valuations…
AG opinion in Arcomet case: VAT implications of transfer pricing adjustments
Recently, the Advocate-General (“AG”) De la Tour of the European Court of Justice provided his opinion in the Arcomet case (C-726/23) on the treatment of transfer pricing adjustments for VAT…
CJEU Rules on the Anti-Abuse Clause in the Parent-Subsidiary Directive: Nordcurrent Case (C-228/24)
On Friday, 5 April, the Court of Justice of the European Union (CJEU) answered the preliminary questions in the case of Nordcurrent Group UAB (Nordcurrent) (C-228/24). The questions concerned the…
Dutch Supreme Court allows liquidation loss despite (possible) prior use Irish relief
On 21 March 2025, the Dutch Supreme Court ruled in favor of a taxpayer claiming a deduction under the Dutch liquidation loss regime. This was despite the fact that the…
Atlas & STP Tax announce merger to strengthen market position and service offering in the Netherlands
Atlas, part of Svalner Atlas Group, is pleased to announce its merger with STP Tax, a leading Dutch tax advisory and compliance firm. This strategic move represents a significant milestone…
Government makes share-based compensation more tax-attractive for startups
The Dutch government is working on a tax reform that will allow startups to reward their employees more favourably with shares or stock options. This decision follows intense lobbying from…
The Netherlands announces tax treaty agenda for 2025
The Dutch Ministry of Finance has published its tax treaty negotiation agenda for 2025, providing insights into recently finalized, ongoing, and upcoming treaty negotiations. This annual update serves to inform…
Svalner Atlas Group continues its expansion by joining forces with KWC in Norway
Svalner Atlas Group is on an expansion journey to become one of the leading independent tax and transaction advisory firms in Northern Europe. As a step on this journey, the…
Findings investigation into the lucrative interest regime
Summary The State Secretary for Finance has informed the Lower House of the Dutch Parliament on the findings of the investigation into the lucrative interest regime. The key takeaway is…
Upcoming Webinar: Pillar Two Update Brazil – 11 Feb 2025
Date: February 11, 2025 Time: 09:00 BRA | 13:00 CET Location: Online Atlas Tax Lawyers, in collaboration with Brazilian tax specialists from Alma Law, is pleased to invite you to…
CJEU Ruling on Dutch Dividend Withholding Tax and Free Movement of Capital
On 7 November 2024, the European Court of Justice (CJEU) delivered a significant judgment (XX, C-782/22) concerning the application of dividend withholding tax (DWT) on foreign insurance companies. The ruling…
Impact of South Africa-Kuwait DTA Changes on Dutch and Swedish Shareholders
Recent adjustments to the double tax agreement (DTA) between South Africa and Kuwait have far-reaching implications that could directly affect the tax liabilities of Dutch and Swedish shareholders of South…
Major tax changes for digital businesses in Canada
Canada has enacted significant changes to its tax regime for businesses operating in the digital economy. Canada’s Digital Services Tax (DST) came into force on 28 June 2024 (legal act…