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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…
Atlas welcomes Taco to the partner team and Yvonne to the counsel team
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…
Frederik Mulder & Matthijs Wierenga beiden genomineerd als Best M&A Tax Advisor 2022
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…
CJEU annuls the EC’s Fiat-Chrysler state aid ruling
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…
The Netherlands publishes draft bill to implement Pillar Two rules
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,…
Budget Day Special – Tax Plan 2023
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: »…
Atlas welcomes Gerben to the partner team
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…
The saga on the withholding tax exemption continues
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…
Update of the 2018 Transfer Pricing Decree
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…
The Transfer Pricing Law Review: Netherlands
An interesting and comprehensive read: The sixth edition of ‘The Transfer Pricing Law Review’. In this edition, our colleagues Taco Wiertsema and Pauline Thio wrote the chapter on transfer pricing…
Proposed amendments to ATAD 3
In December 2021, the European Commission published the anticipated ATAD3 Directive (“Directive”), further cracking down on the use of shell entities in the European Union. Recently, the European Parliament (“EP”) published a…
EU proposes new Directive on debt-equity bias reduction allowance
On 11 May 2022, the European Commission published a draft Directive proposing to introduce harmonized rules in all EU Member States for a more equal treatment of equity and debt…