Tax Lawyers / Fiscalisten

News

Europe's Moment: Repair and Prepare for the Next Generation

Communication from the European Commission The European Commission has unveiled its plan for Europe’s financial recovery from covid-19.The major recovery plan includes the creation of the new instrument “Next Generation…
COVID-19

Atlas Tax Alert on Covid-19 Update 14 May 2020

The coronavirus outbreak does not only have a huge impact on our personal lives, but it has also an enormous impact on the economy and entrepreneurs. In this newsflash we…
COVID-19

The tax/social security impact of COVID-19 on cross-border activities

The COVID-19 pandemic has forced governments to take unprecedented measures such as restricting travel and implementing strict quarantine requirements. As a result of these measures, many cross-border workers are unable…
News

Atlas Tax Lawyers ranked Tier 2 in The Legal 500

Atlas is delighted to announce its Tier 2 position in the 2020 edition of The Legal 500!  Clients appreciate Atlas for: ‘Pragmatic, deal-driven approach, willing to negotiate to get the…
COVID-19 and Transfer Pricing: impact & opportunities
COVID-19

COVID-19 and Transfer Pricing: impact & opportunities

Although MNEs are currently facing challenges that are likely more pressing than taxation/transfer pricing, the current crisis may also provide opportunities in this field. MNEs are advised to investigate these…
COVID-19

Tax accounting and the Corona outbreak: considerations and opportunities

The Corona outbreak may have certain effects on tax accounting. But it may have positive effects on the cash flow position. Mireille Hendrikx, tax accounting expert of Atlas Tax Lawyers,…
COVID-19

Atlas is here for you!

First of all, we wish you and everyone around you strength and to stay healthy in these very difficult times. For Atlas too, safety and health of the team and…
Publications

Economic Analysis and Impact Assessment of the Pillar 1 & 2 Proposals

On 13 February 2020, the OECD published a (first) economic analysis / impact assessment of the (combined) Pillar 1 & 2 proposals). Background The OECD recently published the proposals for…
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…
WTS Global comments on the Unified Approach under Pillar One
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…
Atlas welcomes Frederik Mulder to the partner team
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…
OECD publishes proposal on a “unified approach” to tax the digital economy
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…
International Tax Review ranking - World Tax 2020
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…
Legislative proposal on the Dutch implementation of anti-hybrid rules pursuant to the Anti-Tax Avoidance Directive
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…
Decree published on rulings with an international character
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…
Luis Rosas on secondment to Amsterdam
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.  
Rekening-courantmaatregel mogelijk criminal charge
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…
New State aid investigation into Luxembourg Ruling practice: Huhtamäki
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…
Internetconsultatie ‘Wet excessief lenen bij eigen vennootschap’ bekend als de RC-maatregel
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…
Newsflash: Important decision CJEU on intermediary holding and financing companies
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…
VAT Update for the Digital Economy
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…
Work-related cost rules (WCR) expanded as from 2020
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…
OECD Digital Taxation Solutions
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…
We warmly welcome...
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…
Internet consultation on Dutch implementation EU Anti-Tax Avoidance Directive 2
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 America
News

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…
Jeroen Peters and Xavier Auerbach have been ranked and recognized as notable practitioners by Chambers HNW 2018
News

Jeroen Peters and Xavier Auerbach have been ranked and recognized as notable practitioners by Chambers HNW 2018

Atlas Tax Lawyers is proud to announce that Jeroen Peters and Xavier Auerbach have been ranked and recognized as notable practitioners by Chambers HNW 2018. We warmly congratulate them with…
News

A positive judgement on the VAT position of holding companies in the Marle case on July 5, 2018

Last week, the Court of Justice (“ECJ”) delivered a positive judgement on the VAT position of holding companies in the Marle case on July 5, 2018 (C-320/17).
News

Technical memorandum on the OECD’s non-consensus discussion draft on the transfer pricing aspects of financial transactions

Frank Schwarte, Lennaert Mosk and Mick Willemsen have written a technical memorandum on the recently published, non-consensus, discussion draft on financial transactions. The highly anticipated discussion draft, released by the…
News

OECD releases a discussion draft on the transfer pricing aspects of financial transactions

On July 3, 2018 the OECD released the highly anticipated discussion draft on financial transactions, which deals with the follow-up work in relation to Actions 8-10 of the OECD/G20 Base…
News

Proposal for major overhaul Dutch fiscal unity regime published

In response to the judgment of the EU Court of Justice of 22 February 2018, on 6 June 2018 the Dutch Ministry of Finance published a legislative proposal to amend…
News

Mandatory disclosure directive (DAC 6) on new transparency rules for intermediaries formally adopted

On 25 May 2018, the Council of the EU formally adopted the proposal to strengthen tax transparency of supposedly aggressive cross-border tax planning.
Publications

Netherlands Overhauls Fiscal Unity Regime Following X BV and X NV Judgment

Kristel Tijsterman and Gerbrand Hidding have written an article in edition 90 (May 2018) of the Tax Notes International. In this article Kristel and Gerbrand discuss a recent ruling from the…

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