On this page you will find a selection of news items, events and publications of Atlas.
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Budget Day Special - Tax Plan 2024
This Budget Day Special from Atlas Tax Lawyers outlines important proposals in the Dutch 2024 Tax Plan and additional bills for you. The special is divided into the following topics:…
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Transfer Pricing in Brazil: Practical Aspects in the Adaptation of the Arm’s Length Standard
Brazilian taxpayers need to comply with new OECD-based transfer pricing rules as of financial years starting on or after 1 January 2024. They are also allowed to apply the new…
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Implementation public CbCR in the Netherlands
On 6 July 2023, the Dutch House of Representatives passed legislation to implement public country-by-country reporting under EU directive (EU) 2021/2101. In-scope multinational enterprises (MNEs) are required to publicly disclose…
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Advocate-general opinions on the application of the Dutch dividend withholding tax exemption in 2 Belgian holding company cases
On June 9, 2023, Advocate-General Wattel (hereafter referred to as A-G) issued two opinions in cases concerning the application of the dividend withholding tax (DWT) exemption regarding dividend distributions to…
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New transfer pricing rules in Brazil: opportunities & risks
On 15 June 2023, the provisional measure n. 1152/22 – published on 29 December 2022 – was converted into law with the publishing of Federal Law n. 14.596/23 (the “Law”).…
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Dutch district court allows 25 % tax sparing credit on Brazilian interest on net equity
Earlier this month (on 1 May 2023), the Dutch district court in Breda (“Court”) decided that the Dutch taxpayer X BV has the right to apply a tax sparing credit…
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Webinar: Pillar Two - Deep Dive OECD Safe Harbours
When: February 8, 2023 Time: 4 - 5 pm On December 15, 2022, the EU directive on global minimum taxation (GloBE Rules or Pillar Two) was passed. The OECD subsequently…
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Atlas welcomes Taco to the partner team and Yvonne to the counsel team
We are delighted to announce that Atlas Tax Lawyers has appointed Taco Wiertsema as Partner and Yvonne Bakker as Counsel, as of January 1st, 2023. Taco is a member of…
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CJEU annuls the EC’s Fiat-Chrysler state aid ruling
On 8 November 2022, the Court of Justice of the European Union (CJEU) issued a long-awaited (landmark) decision in the Fiat-Chrysler state aid case. The CJEU set aside the judgement…
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The Netherlands publishes draft bill to implement Pillar Two rules
On October 24, 2022, the Netherlands published the draft bill on Pillar Two called ‘Minimum Tax Rate Act 2024’. This draft bill is open for public consultation until December 5,…
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Budget Day Special - Tax Plan 2023
This Budget Day Special from Atlas Tax Lawyers outlines important proposals in the Dutch 2023 Tax Plan and additional legislative proposals. The special is divided into the following topics: »…
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Atlas welcomes Gerben to the partner team
We are delighted to announce that Atlas Tax Lawyers N.V. (Atlas) has appointed Gerben Markink as a Partner Indirect Tax as of September 1st, 2022. Since 2013, he is a…
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The saga on the withholding tax exemption continues
Interested in the outcome of the Amsterdam Court of Appeal on a distribution to a Belgian family holding company? Our colleagues, Dennis Kamps, Steven Vijverberg and Ivo Kuipers have written…
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Update of the 2018 Transfer Pricing Decree
Today, the Dutch State Secretary of Finance published an update of the 2018 Transfer Pricing Decree (in Dutch). The 2022 Decree provides the further details on the application of the…
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The Transfer Pricing Law Review: Netherlands
An interesting and comprehensive read: The sixth edition of ‘The Transfer Pricing Law Review'. In this edition, our colleagues Taco Wiertsema and Pauline Thio wrote the chapter on transfer pricing…
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Proposed amendments to ATAD 3
In December 2021, the European Commission published the anticipated ATAD3 Directive (“Directive"), further cracking down on the use of shell entities in the European Union. Recently, the European Parliament (“EP”) published a…
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EU proposes new Directive on debt-equity bias reduction allowance
On 11 May 2022, the European Commission published a draft Directive proposing to introduce harmonized rules in all EU Member States for a more equal treatment of equity and debt…
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Brazil and the Netherlands agree on the qualification of Brazilian ‘interest on net equity’ under the bilateral tax treaty
By way of a Mutual Agreement Procedure (“MAP”), the Netherlands and Brazilian Competent Authorities have reached consensus on the qualification of Brazilian ‘interest on net equity (Juros sobre o Capital…
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2nd part - Colombia and the Netherlands signed a double tax treaty
On February 16, 2022, Colombia and the Netherlands signed a double tax treaty (DTT). Now that the text of the DTT has been published, we can update you in our…
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Taxation of Artwork webinar – March 22, 2022
We are pleased to invite you to the following high-caliber webinar: Taxation of Artwork. On March 22, 2022, from 16:30 - 18:00 CET, WTS Global will organize their first webinar…
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March 17: Women of IFA Network Bilateral Tax Conference Germany - The Netherlands
The Women of IFA Network (WIN) represents and connects the many professional women working in international tax. On March 17th, WIN is organizing a Bilateral Tax Conference between Germany and…
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Colombia and the Netherlands signed a double tax treaty
On February 16, 2022, The Netherlands and Colombia signed a double tax treaty (DTT). Before the treaty enters into force, the mandatory approval procedure must still be completed in both…
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Taxation crypto currencies in the Netherlands: what are the tax consequences for taxpayers who own crypto currencies?
On 24 December 2021, the Dutch Supreme Court ruled that the personal income tax levy on income from savings and investment, in 2017 and 2018, violated property rights and the…
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The VAT Treatment of Online Events in the EU
The European Commission has been working on a proposal to apply reduced VAT rates since 2018. In December 2021, the Council of the European Union reached an agreement on a…
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The ATAD3 Directive – The crackdown on EU ‘Shell entities’
On 22 December 2021, the European Commission published the anticipated ATAD3 proposal, further cracking down on the use of shell entities in the European Union. Steven Vijverberg and Dennis Kamps…
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OECD publishes Pillar Two Model Rules for Domestic Implementation of 15% Global Minimum Tax
The OECD published detailed Model Rules to assist the implementation of a reform to the international tax system, commonly referred to as Pillar Two. This ensures that from 2023, Multinational…
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"eHerkenning" required as of 2022 for filing VAT returns and (M)OSS returns
As of January 2022, eHerkenning is required if a VAT entrepreneur files its VAT returns and (M)OSS returns via de online portal of the Tax authorities. eHerkenning is a new…
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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…
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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…
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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.…
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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…
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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…
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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…
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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…
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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…
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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…
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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…
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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…
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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…
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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…
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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…
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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…
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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…
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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…
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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).…
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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,…
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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…
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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.
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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…
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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…
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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…
