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Frederik Mulder nominated for Best M&A Tax Advisor 2021!

Frederik Mulder has been nominated for Best M&A Tax Advisor! We are very proud of Frederik, the Atlas M&A team and the fantastic deals that made this nomination possible! Our…

G20 leaders called on to develop model rules and multilateral instruments - Global roll out in 2023

OECD Secretary-General Mathias Cormann welcomed the G20 Leaders’ Declaration, recognising the historic tax agreement reached by the OECD/G20 Inclusive Framework on Base Erosion and Profit Shifting (BEPS). At their summit in…

A welcome proposal to take away some of the overkill of the Dutch ATAD2 anti-hybrid rules

On 25 October 2021, a Dutch member of parliament submitted a proposal for a legislative amendment aimed at taking away some of the overkill of the Dutch ATAD2 anti-hybrid rules.…

OECD announcement: 136 jurisdictions have joined the Statement on the Two-Pillar Solution

On October 8th, the OECD announced that 136 jurisdictions (out of the 140 members of the OECD/G20 Inclusive Framework on BEPS) have joined the Statement on the Two-Pillar Solution to…

Publications

The ATAD general anti-avoidance rule in the Netherlands

The Dutch legislator decided not to implement the General Anti-Avoidance Rule (“GAAR”) of the EU Anti-Tax Avoidance Directive (“ATAD”) and to rely on the court developed fraus legis doctrine.    As there are several…

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…

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…

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…

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