Tax Lawyers / Fiscalisten

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Internet consultation on Dutch implementation proposal EU Anti-Tax Avoidance Directive

On 10 July 2017, the Dutch Government published a preliminary proposal for consultation to implement the Anti-Tax Avoidance Directive measures (ATAD1) as adopted by the EU in June 2016. The…
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OECD releases latest updates to the Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations

On July 10, 2017 the OECD released the 2017 edition of the OECD Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations (Transfer Pricing Guidelines). The Transfer Pricing Guidelines provide…
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OECD releases BEPS discussion drafts on attribution of profits to permanent establishments and transactional profit splits

OECD releases BEPS discussion drafts on attribution of profits to permanent establishments and transactional profit splits On June 22, 2017 the OECD released two public discussion drafts, containing guidance on…
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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…
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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…
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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”…
Publications

VAT and Directors’ Fees in the Benelux

The VAT Directive does not clearly address the question of the VAT treatment of directors’ fees, and recent developments in Dutch, Belgian and Luxembourg VAT legislation have emphasized the lack…
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…
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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…
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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…
News

30 March - 31 March 2017 | Indirect TAX Forum

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…
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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…
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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…
Publications

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

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…
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We are proud to announce...

...A new partner: Kristel Tijsterman.
News

Dutch deemed salary rule under the application of double tax treaties

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…
News

Further clarifications published on proposed amendments to Dutch dividend withholding tax act

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…
News

VAT treatment of unpaid invoices

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…
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

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…

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