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Atlas welcomes Frederik Mulder to the partner team
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…
OECD publishes proposal on a “unified approach” to tax the digital economy
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…
International Tax Review ranking – World Tax 2020
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…
Introduction withholding tax on interest and royalty payments
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…
TP and credit ratings: The impact of passive association
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…
TP and credit ratings: Establishing the stand-alone credit profile
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…
Atlas Tier 2 in the 2019 Tax Advisory Survey of ITR
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…
TP and credit ratings: Determining the anchor rate
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…
Legislative proposal on the Dutch implementation of anti-hybrid rules pursuant to the Anti-Tax Avoidance Directive
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…
Decree published on rulings with an international character
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…
Commissaris is (toch) niet btw-plichtig
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…
Impact CJEU ‘Danish cases’ to Dutch anti-abuse rules
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.
Digital Taxation – OECD Released Workplan
On 31 May 2019, the Organisation for Economic Co-operation and Development (OECD) released a Workplan (“Programme of Work to Develop a Consensus Solution to the Tax Challenges Arising from the Digitalisation of the Economy”) setting out a process to reach a new global agreement on future taxation of multinational enterprises. The workplan aims to resolve the tax challenges arising from the global digitalisation of economies and explores technical issues to be resolved through two main pillars (see our newsalert here on the two main pillars).
Luis Rosas on secondment to Amsterdam
We are happy to welcome Luis Rosas from Mexico to our office for a three months secondment. He is working for Turanzas, Bravo & Ambrosi, the WTS member firm in…
New draft ruling policy in the Netherlands
In December 2018 the Dutch State Secretary of Finance announced that he would introduce a new policy for obtaining tax rulings with an international character. On 23 April 2019 a…