On this page you will find a selection of news items, events and publications of Atlas.
News
Atlas continues to expand!
We have not lounged around since the announcement last year of our Benelux cooperation with the Belgium-Luxembourg lawfirm Tiberghien under the T/A international umbrella. Since the announcement, our transfer pricing and valuation…News
Revision period for valuable services
Revision period for valuable services As early as 2005 a parliamentary bill has been submitted regarding the implementation of a revision period towards valuable services. This regulation should be an…News
Preliminary proposal to amend the dividend withholding tax regime
The Dutch Deputy Minister of Finance published a preliminary tax proposal for consultation on 16 May 2017 with proposed changes to the Dutch Dividend Tax Act. These changes include a…Events
May 11, 2017, Amsterdam
11 May 2017 | 15th Brazil Seminar
In its efforts to strengthen ties between Brazil and the Netherlands, Atlas’ Brazilian Desk is promoting with BRADUTCH (the Brazilian Dutch Chamber) the seminar “Agribusiness Locomotive for Brazil Trade Mission”…News
Supreme Court clarifies abuse of law doctrine and counterevidence anti-base erosion rules
In April 2017, the Dutch Supreme Court issued four rulings in ten cases on tax planning structures set up by the international banking group Credit Suisse. The rulings of the…News
Atlas assists argenx with Dutch tax agreement regarding business restructuring
A team of Atlas Tax Lawyers led by Matthijs Wierenga (tax partner) and Frank Schwarte (transfer pricing partner) has assisted the biotech company argenx reach an agreement with the Dutch…News
Hybrid mismatches with third countries
On 21 February 2017, the EU Member States reached an agreement on the proposed amendments to the Anti-Tax Avoidance Directive (“ATAD”). One of objectives of this new Directive (“ATAD 2”)…News
Initial position of the Netherlands on OECD BEPS Multilateral instrument
On 21 March 2017, the Dutch Ministry of Finance submitted a letter to Parliament confirming their views regarding the Multilateral Instrument (“MLI”). The position of the Netherlands is in line…News
EJC ruled on application Parent-Subsidiary Directive for Dutch investment institution
Recently the European Court of Justice (“EJC”) ruled that a Dutch fiscal investment institution (Fiscale beleggingsinstelling or “FBI”) is not entitled to invoke the Parent-Subsidiary Directive (90/435/EEG) (“Directive”) as a…News
Draft bill on implementation UBO register
On March 31, 2017 a draft bill on the implementation of the Ultimate Beneficial Owner (UBO) register was presented for public consultation. The bill results from the European Directive 2015/849…Events
30 March - 31 March 2017 | Dusseldorf
Indirect TAX Forum
Speaker: Dirk Evers & Leonie de Rooij
Dirk Evers and Leonie de Rooij will be attending Indirect TAX Forum 2017 in Düsseldorf. Please find more information here and click here to download the brochure. We hope to…
Events
14 March - 17 March 2017 | MIPIM Cannes
Bas Leensma and Joël Wessels will be attending MIPIM in Cannes, France. We hope to see you there!News
Updated Decree Participation Exemption released
A new Decree Participation Exemption (the “Decree”), dated 20 January 2017, has been released. The Decree describes further guidelines on the participation exemption regime and replaces the previous Decree of…News
Atlas establishes a Brazilian Desk
Atlas Tax Lawyers is pleased to announce it has established a Brazilian Desk. The desk will be headed by both Brazilian tax lawyer Martha Formenti, new associate at Atlas, and…News
Opinion Advocate General of Dutch Supreme Court on scope Dutch base erosion rules (article 10a CITA)
Recently the Advocate General (“AG”) rendered its opinion on the Dutch interest deduction limitation rule of article 10a CITA. According to the AG article 10a CITA is also applicable in…News
Agreement on the proposed amendments to the Anti-Tax Avoidance Directive
On 21 February 2017, the Ecofin reached an agreement on the proposed amendments to the Anti-Tax Avoidance Directive (“ATAD”) which neutralizes the effects of hybrid mismatches between EU members states…News
T/A economics: Painting a new story...
... as the BeNeLux alternative for transfer pricing and valuation services, yet with a distinct approach. Atlas and Tiberghien are pleased to announce the launch of T/A economics, a joint…News
The post-BEPS advantages of the Netherlands
Roelof Gerritsen and Ivo Kuipers, both partners at Atlas Tax Lawyers in the Netherlands, look at why the country will remain a prime location for multinationals and foreign investors as…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…News
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…News
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.…News
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…News
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…News
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…News
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…News
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…News
Netherlands postpones deadline for CbCR notification
On Monday November 21, 2016, the Dutch State Secretary of Finance announced he is postponing the deadline for the country-by-country-reporting notification.News
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.Events
17 - 18 November 2016 | Koninklijke Industrieele Groote Club in Amsterdam
IBA Conference: The New Era of Taxation
Speaker: Ivo Vande Velde (Tiberghien)
Ivo VANDE VELDE will participate in the panel discussion on Exit Taxation at the upcoming IBA Conference in Amsterdam (17 and 18 November) on The New Era of Taxation. The panel will…
