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Tax developments that are relevant for Dutch real estate market
In this comprehensive overview, we delve into the latest tax developments impacting the Dutch real estate market, highlighting key changes and their implications for investors, developers, and stakeholders. From the…
OECD releases the report on Pillar One Amount B
Background On February 19, 2024, the OECD/G20 Inclusive Framework on BEPS released the report on Amount B of Pillar One. Amount B attempts to streamline and simplify the process of…
Amending marriage contract shortly before passing away: pay inheritance tax or not?
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…
New guidance on entity classification rules
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…
Tax Plan 2024: adjustments and reduction of the 30% ruling
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…
Atlas welcomes Arthur Smeijer as Counsel
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…
Dutch Court reaffirms 25% tax credit for Brazilian equity interest
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…
Reporting requirement work-related personal mobility
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…
Budget Day Special – Tax Plan 2024
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:…
Transfer Pricing in Brazil: Practical Aspects in the Adaptation of the Arm’s Length Standard
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…
Implementation public CbCR in the Netherlands
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…
Advocate-general opinions on the application of the Dutch dividend withholding tax exemption in 2 Belgian holding company cases
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…
New transfer pricing rules in Brazil: opportunities & risks
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”).…
Dutch district court allows 25 % tax sparing credit on Brazilian interest on net equity
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…
Webinar: Pillar Two – Deep Dive OECD Safe Harbours
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…