Tax Lawyers / Fiscalisten

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

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…
The International Tax Review (ITR) 2022 is now live!
News

The International Tax Review (ITR) 2022 is now live!

The International Tax Review (ITR) 2022 is now live! We are very proud of our team and we are pleased to announce that Atlas has been ranked tier 1 and…
Budget Day Special - 2022 Tax Plan
News

Budget Day Special - 2022 Tax Plan

Tuesday 21 September 2021, it was Budget Day in the Netherlands. Interested to find out more about the new tax proposals and the impact? Please click here for the full…
The Transfer Pricing Law Review – An overview of the main transfer pricing rules in key jurisdictions worldwide
News

The Transfer Pricing Law Review – An overview of the main transfer pricing rules in key jurisdictions worldwide

Our colleagues Taco Wiertsema and Anne Verhagen contributed to the 5th edition of the Transfer Pricing Law Review. This publication contains the unique accounts of legislation across jurisdictions from the…
Landmark case on deductibility of intercompany interest
News

Landmark case on deductibility of intercompany interest

On 16 July 2021, the Dutch Supreme Court released its judgement on the application of the abuse of law to the deductibility of interest. The case concerned a private equity…
The OECD/G20 Inclusive Framework on Base Erosion and Profit Shifting (IF) has agreed a two-pillar solution
News

The OECD/G20 Inclusive Framework on Base Erosion and Profit Shifting (IF) has agreed a two-pillar solution

The OECD issued a statement on July 1, 2021. The OECD/G20 Inclusive Framework on Base Erosion and Profit Shifting (IF) has agreed a two-pillar solution to address the tax challenges…
Torqx Capital Partners acquires majority of the shares of VHE Industrial automation
News

Torqx Capital Partners acquires majority of the shares of VHE Industrial automation

Congratulations to Torqx Capital Partners for acquiring the majority of the shares of VHE Industrial automation in partnership with current shareholders Joop Essing and Marc van Happen. VHE Industrial automation…
The G7 Finance Ministers Agree Historic Global Tax Agreement
News

The G7 Finance Ministers Agree Historic Global Tax Agreement

According to the press release dated June 5, 2021, the G7 finance ministers reached agreement on a global coordinated tax reform. The global tax reform is closely related to the…
European Commission Communication on Business Taxation for the 21st century
News

European Commission Communication on Business Taxation for the 21st century

On 18 May 2021, the European Commission (“EC”) published the long-awaited Communication on Business Taxation for the 21st Century (the “Communication”). The Communication provides a roadmap with short- and long-term…
President Biden’s “Made in America Tax Plan” and proposed changes to US tax law for multinationals
News

President Biden’s “Made in America Tax Plan” and proposed changes to US tax law for multinationals

In the recent Made in America Tax Plan, the Biden administration proposes fundamental reforms to the US tax code. At the same time, a surprising shift in stance on the…
International Lessons from Coca-Cola
News

International Lessons from Coca-Cola

Our TP experts Taco Wiertsema and Anne Verhagen wrote the article “International Lessons from Coca-Cola” for Tax Notes. The article provides for a critical analysis of the U.S. Tax-Court’s recent…
The tax and social security impact of COVID-19 on cross-border activities
News

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

The ongoing COVID-19 pandemic has forced governments to take unprecedented measures such as travel restrictions and the implementation of strict quarantine requirements. As a result of these measures, some cross-border…
Proposal to Disallow Unilateral Downward Transfer Pricing Adjustments
News

Proposal to Disallow Unilateral Downward Transfer Pricing Adjustments

Yesterday, the Dutch Ministry of Finance kicked-off an internet consultation on a draft proposal (the “Draft Bill”) to amend the Dutch codification of the arm’s length principle. The Draft Bill…
Services provided by datacenters are not services relating to real property
News

Services provided by datacenters are not services relating to real property

For VAT purposes, services supplied by datacenters should not qualify as services related to real property. For an overview of the recent developments relating to the vat qualification of services…
The CJEU rules against the Swedish interest deduction limitation rules
News

The CJEU rules against the Swedish interest deduction limitation rules

Last month, the Court of Justice of the European Union (CJEU) issued a preliminary ruling on the compatibility of a Swedish interest deduction limitation rule in the Lexel case (c-485/19).…
ATAD2 and the Dutch Documentation Requirement
News

ATAD2 and the Dutch Documentation Requirement

The Anti-Tax-Avoidance-Directive II (“ATAD2”) has been implemented in the Dutch legislation with effect from 1 January 2020.  The ATAD2 provisions, which aim to neutralize certain tax effects of hybrid mismatches,…
Chile and the Netherlands sign a double tax treaty
News

Chile and the Netherlands sign a double tax treaty

On 25 January 2021, Chile and the Netherlands signed a double tax treaty (DTT). This is a welcome addition to the Dutch tax treaty network facilitating Dutch companies with doing…
Comments Atlas Tax Lawyers on the OECD Public Consultation Document regarding BEPS Action 14
News

Comments Atlas Tax Lawyers on the OECD Public Consultation Document regarding BEPS Action 14

Last week Atlas Tax Lawyers provided its comments on the OECD Consultation Document (the “Consultation Document”) regarding BEPS Action 14.
Atlas Tax Lawyers advised Cellnex Telecom S.A. and Deutsche Telekom Capital Partners on the merger of Deutsche Telekom’s tower business in the Netherlands with Cellnex Netherlands and the funding of a new Digital Infrastructure Vehicle
News

Atlas Tax Lawyers advised Cellnex Telecom S.A. and Deutsche Telekom Capital Partners on the merger of Deutsche Telekom’s tower business in the Netherlands with Cellnex Netherlands and the funding of a new Digital Infrastructure Vehicle

Atlas Tax Lawyers advised Cellnex Telecom S.A. and Deutsche Telekom Capital Partners on the merger of Deutsche Telekom’s tower business in the Netherlands with Cellnex Netherlands and the funding of…
Atlas welcomes Johan Visser to the partner team
News

Atlas welcomes Johan Visser to the partner team

With great pleasure we announce the appointment of Johan Visser as partner as of January 1st 2021. He has been part of the firm since 2018 and is specialized in…
Dutch Budget proposals 2021 approved by the Senate
News

Dutch Budget proposals 2021 approved by the Senate

Last week the Dutch Budget 2021 was approved by the Senate (”Eerste Kamer”). Today publication in the State Gazette took place. As such, changes in Dutch corporate income tax law…
News

Latest case law on beneficial ownership and abuse of law

Recent case law across Europe shows that domestic courts are being inspired by the CJEU case law on abuse. In this newsletter we have summarised recent case law in Switzerland,…
News

Legislative proposal loss compensation rules

At the beginning of this week, on 5 October, the Dutch Ministry of Finance submitted a proposal to parliament regarding changes to the loss compensation rules for Dutch corporate taxpayers.…
News

Dutch government announces limitation to unilateral downward transfer pricing adjustments

In the scope of the 2021 Tax Plan, the Dutch Ministry of Finance announced its intention to introduce a bill of law which will limit unilateral downward transfer pricing adjustments…
News

Atlas Budget Day Special 2020

The Budget Day Special of Atlas Tax Lawyers outlines the most relevant proposals in the 2021 Tax Plan and additional legislative proposals. In this special the following topics will be…
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…
News

EU General Court judgment

In 2016, the European Commission argued that the Irish tax authorities, as a result of its tax rulings, allowed the Irish permanent establishments of two Apple companies unlawful State aid…
Tax Loss Carryback - Global Insights
COVID-19

Tax Loss Carryback - Global Insights

The COVID-19 pandemic has created significant uncertainty forbusinesses worldwide and the real impact on companies is stillemerging. Many companies are facing the spectre of losses andare looking for enhanced liquidity,…
News

The Netherlands agrees on six months deferral of DAC6 reporting deadlines

The State Secretary of Finance of the Netherlands announced that, due to the Covid-19 outbreak, the reporting obligation on cross-border tax planning arrangements will be postponed from 1 July 2020…
News

Transfer Pricing Newsletter now available

The first issue of the WTS Transfer Pricing Newsletter provides you with an update on the recent news and cases in the field of transfer pricing in 14 countries as…
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…

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