Tax Lawyers / Fiscalisten

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”…

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…

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…

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”)…

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…

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…

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…
30 March - 31 March 2017 | Dusseldorf

Indirect TAX Forum

Speaker: Dirk Evers & Leonie de Rooij
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…

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!

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…

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…

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…

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…

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…

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…

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…

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 of the OECD’s BEPS project (Action…

We are proud to announce...

...A new partner: Kristel Tijsterman.

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 the application of the tax treaty between the Netherlands and Portugal.…

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 withholding tax position of Dutch Cooperatives (currently not being subject to Dutch…

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 issues an invoice charging VAT…

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…

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 BEPS projects in the bilateral tax…

Dutch government responds on proposal ATAD and hybrid mismatches with third countries

The Dutch government responds on the amendments to the Anti-Tax Avoidance Directive (“ATAD”) proposed by the European Commission last month. The proposal in particular addresses the neutralisation of hybrid mismatches…

Netherlands postpones deadline for CbCR notification

On Monday November 21, 2016, the Dutch State Secretary of Finance announced he is postponing the deadline for the country-by-country-reporting notification.  

Leading Firms

Atlas is proud to announce that we will again be one of the leading companies in Tier 3 of the ITR this year.
17 - 18 November 2016 | Koninklijke Industrieele Groote Club in Amsterdam

IBA Conference: The New Era of Taxation

Speaker: Ivo Vande Velde (Tiberghien)
Ivo VANDE VELDE will participate in the panel discussion on Exit Taxation at the upcoming IBA Conference in Amsterdam (17 and 18 November) on The New Era of Taxation. The panel will…

7 March - 10 March 2017 | TP Minds International London

Frank Schwarte and Andy Neuteleers will be attending TP Minds International in London.  We hope to see you there!

2017 Luxembourg Tax Reform | Draft law

On 26 July 2016 the Luxembourg Government submitted the draft law no. 7020 to the Luxembourg Parliament. The draft law includes a number of direct and indirect tax measures, most…

25 September - 30 September 2016 | Madrid IFA Congress

Kristel Tijsterman, Jan Willem Lubbers and Ivo Kuipers will be attending the 70th IFA Congress in Madrid. Tiberghien will be there as well with a delegation from Belgium and Luxembourg.…

17 November - 18 November 2016 | Amsterdam IBA Conference

IBA Conference: The New Era of Taxation: What You Need to Know in a Constantly Changing World. Both Atlas and Tiberghien will be attending this conference in Amsterdam. We hope…

Recent case law: interest deduction limitation to prevent base erosion

On 5 June 2016 and on 8 July 2016, the Dutch Supreme Court decided in two important cases on the rebuttal rules in the interest deduction limitation to prevent base…

The end of withholding tax on gross basis!: ECJ decision in Brisal Case

On July 13, 2016 the European Court of Justice rendered a milestone decision on withholding tax on interest payments within the EU (case C-18/15, Brisal – KBC Finance Ireland).

Dutch tax consequences “per element approach” Groupe Steria case

On 8 July, 2016, the Dutch Supreme Court has requested the ECJ to clarify whether the ‘per-element approach’ adopted by the ECJ in the Groupe Steria case is (and to…

Netherlands: The advantages of a Dutch holding company

In recent times, there has been increasing interest in the Netherlands from multinational companies that wish to avoid supposed tax havens and blacklisted jurisdictions. Roelof Gerritsen and Ivo Kuipers of…


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