On this page you will find a selection of news items, events and publications of Atlas.
Publications
OECD releases Transfer Pricing Guidance on Financial Transactions
On February 11, 2020 the OECD released the highly anticipated report “Transfer Pricing Guidance on Financial Transactions” (“the report”), which deals with the follow-up work in relation to Actions 8-10…Publications
Abuse of Law under EU Directives - Derivatives & Financial Instruments, 2019 (Volume 21), No. 6
In this article the authors Frederik Mulder and Yves Cattel discuss the ruling of the European Court of Justice in the so-called “Danish cases” (T Danmark – Case C-116/16 and…
News
WTS Global comments on the Unified Approach under Pillar One
On November 12th, the WTS Global comments on the Unified Approach under Pillar One were sent to the OECD. Atlas, represented by Ivo Kuipers, Joris Steunenberg en Mick Willemsen, was…
News
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…
News
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…
News
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…Events
Amsterdam, 16 October
WTS Global: Asia Roadshow 2019
Asian Responses to BEPS, DigitalAsian Responses to BEPS, DigitalTax and Growing Trade Tensions. 14 October 2019 (Paris) | 15 October 2019 (Brussels) | 16 October 2019 (Amsterdam) Please use…News
Amsterdam, 18 September 2019
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…News
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…News
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…News
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…Events
26-27 September 2019 | 8.45 a.m. - 3.50 p.m. | NH Grand Hotel Krasnapolsky Amsterdam
Global Transfer Pricing Forum - Europe 2019
Speaker: Andy Neuteleers (T/A economics and WTS Global Belgium)
News
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…
News
Amsterdam
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…
News
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…News
Amsterdam
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…News
Amsterdam
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…News
Amsterdam
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…
News
Amsterdam
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…News
Amsterdam
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…News
Amsterdam
Internet consultation limitation of current liquidation loss scheme
Internet consultation limitation of current liquidation loss scheme Three members of the Dutch House of Representatives jointly prepared a legislative proposal that should limit the current liquidation loss scheme (applicable…News
Amsterdam
Atlas, Tiberghien and T/A economics establish global supply chain tax group
Over the past years, Atlas, Tiberghien and T/A economics have been working towards the formation of a full-scope global supply chain tax group. With the most recent hires of customs…News
Amsterdam
Custom expert Gooike van Slooten joins Atlas
Custom expert Gooike van Slooten joins Atlas Over the last few months Atlas continued growing its Indirect Tax and Customs practice. After global Indirect Tax experts Johan Visser and Dasha…News
Legal 500 ranking
Atlas is very proud of its new position in Tier 2 of the Legal 500 Firm ranking! We want to thank our clients and the whole Atlas team. Click here…News
Amsterdam
Update UBO-register: implementatiewetsvoorstel ingediend bij Tweede Kamer
Op 4 april 2019 is de “Implementatiewet registratie van uiteindelijk belanghebbenden van vennootschappen en andere juridische entiteiten” (het UBO-register) bij de Tweede Kamer ingediend.
News
Amsterdam
Rekening-courantmaatregel mogelijk criminal charge
Op Prinsjesdag 2018 heeft het kabinet Rutte-III een rekening-courantmaatregel aangekondigd, op grond waarvan DGA’s in box 2 inkomstenbelasting verschuldigd worden over de (niet-eigenwoning)schulden aan hun eigen BV, voor zover deze…
News
Amsterdam
New State aid investigation into Luxembourg Ruling practice: Huhtamäki
On 7 March 2019, the European Commission (“EC”) opened a formal State aid investigation into tax rulings granted by the Luxembourg tax authorities (“LTA”) to a Huhtamäki group company, Huhtalux…
News
Amsterdam
Internetconsultatie ‘Wet excessief lenen bij eigen vennootschap’ bekend als de RC-maatregel
Op maandag 4 maart 2019 is de internetconsultatie gestart van de ‘Wet excessief lenen bij eigen vennootschap’ Wij berichtten u eerder over de door het kabinet Rutte-III op Prinsjesdag 2018…
News
Amsterdam
Newsflash: Important decision CJEU on intermediary holding and financing companies
On 26 February 2019 the Court of Justice of the European Union (“CJEU”) released its long awaited judgement with respect to the so-called ‘Danish beneficial ownership cases’. The Danish beneficial…
Publications
VAT Update for the Digital Economy
The final weeks of 2018 week proved to be important for online service providers, webshops and online marketplaces. The VAT Committee published two so called working papers in which it…
News
Amsterdam, 7 February 2019
Work-related cost rules (WCR) expanded as from 2020
As from 2020 employers can provide up to EUR 2,000 extra tax-free benefits towards their employees as a result of new legislation announced by the government last week. The so-called…
News
Amsterdam, 4 February 2019
OECD Digital Taxation Solutions
On 29 January 2019, the Organisation for Economic Co-operation and Development (OECD) released a Policy Note on its work to address the tax challenges of the digitalisation of the economy…News
Amsterdam
New State aid investigation into Dutch Ruling practice: Nike
On 10 January 2019, the European Commission (“EC”) opened a formal State aid investigation into tax rulings granted by the Dutch tax authorities (“DTA”) to two Nike group companies, European…News
Amsterdam
Newsflash: The Netherlands unilaterally introduces a list of low-taxed jurisdictions
The Netherlands has unilaterally published a list of low-taxed jurisdictions. This list will have an impact on the application of the newly introduced CFC rules, on the proposed withholding tax…News
Amsterdam
Alert: CJEU’s decision in its case MEO – Serviços de Comunicações e Multimédia SA
Qualification of an early termination payment for the purposes of VAT The CJEU has decided that an early termination payment made by a client to a telecom service provider must…
News
We warmly welcome...
We warmly welcome Boudewijn Niels among our partner team, taking effect on 1 January 2019. Boudewijn is specialized in tax aspects of private equity and M&A transactions. Additionally, he has…News
Newsflash: Proposed changes to Dutch ruling practice
Last week, on 22 November 2018, the State Secretary of Finance published a letter in which he described the contemplated changes to the current tax ruling practice. According to the…
News
Internet consultation on Dutch implementation EU Anti-Tax Avoidance Directive 2
On 29 October 2018, the Dutch Government published a consultation document regarding the implementation of the Anti-Tax Avoidance Directive measures (“ATAD 2”) as adopted by the EU in May 2017.…News
VAT and holding companies: European Court of Justice accepts the right to deduct input VAT on broken-deal costs
On 17 October 2018 the Court of Justice of the European Union (‘CJEU’) rendered its decision in the Ryanair case (C-249/17). This decision handles the issue of input VAT recovery…News
The Netherlands: Revised Tax Plan 2019
On Budget Day (18 September 2018), the new tax measures for 2019 and further were published. Earlier this week, on 15 October 2018, the Dutch government announced that its initial…News
The Netherlands: Tax Plan 2019
On Budget Day (18 September 2018), the Dutch government published the new tax measures for 2019 and beyond. The package also includes the long-awaited proposals for the implementation of ATAD1,…News
Introduction Withholding Tax Act 2020
On Budget Day 2018, the Dutch government released its much debated proposal to abolish the dividend withholding tax of 15% as of 2020. Instead of the current provisions, a new…News
Implementation of ATAD1 In Dutch Tax Law
On Budget Day, the Dutch government submitted a legislative proposal regarding the implementation of the Anti-Tax Avoidance Directive as agreed mid 2016 by the EU member states (“ATAD1”). The most…News
WTS Global opens US desk in New York and San Francisco
WTS Global opens US desk in New York and San Francisco to further strengthen its footprint in North AmericaNews
European Court of Justice rules on VAT treatment Payment Services
With the rise of eCommerce, online platforms and FinTech the use of payment services or payment service providers, has substantially increased. As most (online) platforms, eCommerce platforms or applications and…
