Tax Lawyers / Fiscalisten

News

Luxembourg introduces new rules applicable to intra-group financing companies – rules applicable as from 1 January 2017

1. IntroductionThe Luxembourg direct tax authorities issued on 27 December 2016 new guidelines by means of the issuance of Circular L.I.R. no. 56/1 – 56bis/1 (hereinafter the “Circular”) which deals…
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New innovationbox regime in The Netherlands

As announced earlier in 2016, the Netherlands has enacted a new innovation box regime as of January 1, 2017, in line with the outcomes of the OECD’s BEPS project (Action…
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We are proud to announce...

...A new partner: Kristel Tijsterman.
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Dutch deemed salary rule under the application of double tax treaties

The Dutch Supreme Court has recently decided that the Netherlands could not apply the domestic deemed salary rule under the application of the tax treaty between the Netherlands and Portugal.…
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Further clarifications published on proposed amendments to Dutch dividend withholding tax act

In addition to our recent news alert in relation to the proposed amendments to the current Dutch dividend withholding tax position of Dutch Cooperatives (currently not being subject to Dutch…
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VAT treatment of unpaid invoices

VAT is due on the supply of VAT taxable services or goods. The supplier pays the VAT due to the Dutch Tax Authorities (‘DTA’) and issues an invoice charging VAT…
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Ecofin has not yet reached an agreement on the proposed amendment of the ATAD regarding Hybrid Mismatches with third countries

Ecofin has not yet reached an agreement on the proposed amendment of the ATAD regarding Hybrid Mismatches with third countries On 6 December 2016, the Ecofin did not come to…
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Multilateral instrument to implement BEPS measures

A group of more than 100 jurisdictions have agreed upon a multilateral instrument (“MLI”) for the implementation of certain tax treaty measures of the BEPS projects in the bilateral tax…
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Dutch government responds on proposal ATAD and hybrid mismatches with third countries

The Dutch government responds on the amendments to the Anti-Tax Avoidance Directive (“ATAD”) proposed by the European Commission last month. The proposal in particular addresses the neutralisation of hybrid mismatches…
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Leading Firms

Atlas is proud to announce that we will again be one of the leading companies in Tier 3 of the ITR this year.
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2017 Luxembourg Tax Reform | Draft law

On 26 July 2016 the Luxembourg Government submitted the draft law no. 7020 to the Luxembourg Parliament. The draft law includes a number of direct and indirect tax measures, most…
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Recent case law: interest deduction limitation to prevent base erosion

On 5 June 2016 and on 8 July 2016, the Dutch Supreme Court decided in two important cases on the rebuttal rules in the interest deduction limitation to prevent base…
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The end of withholding tax on gross basis!: ECJ decision in Brisal Case

On July 13, 2016 the European Court of Justice rendered a milestone decision on withholding tax on interest payments within the EU (case C-18/15, Brisal – KBC Finance Ireland).
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Dutch tax consequences “per element approach” Groupe Steria case

On 8 July, 2016, the Dutch Supreme Court has requested the ECJ to clarify whether the ‘per-element approach’ adopted by the ECJ in the Groupe Steria case is (and to…
Publications

Netherlands: The advantages of a Dutch holding company

In recent times, there has been increasing interest in the Netherlands from multinational companies that wish to avoid supposed tax havens and blacklisted jurisdictions. Roelof Gerritsen and Ivo Kuipers of…

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