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Re-domiciliations and cross-border mergers can be great options for a restructuring and, within the EU, the rules governing both types of...
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In order to carry out a transaction, taxpayers are generally free to choose between different structures and tax regimes, and to choose...
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Within the Netherlands, there are various anti-abuse or anti-avoidance rules containing purpose tests. Most relevant within the context...
Across a number of European jurisdictions, relief from withholding tax may be denied where the recipient of a dividend, interest or...
In the Netherlands, the term beneficial owner can arguably have two different meanings: a domestic law meaning and a tax treaty law...
In a previous post, Maarten van der Weijden indicated that a decision by the Amsterdam Court of Appeal on 22 December 2020 set the stage...
The global tax treaty network has historically consisted of bilateral tax treaties. Updating a bilateral tax treaty network has been...
Multinational companies increasingly face situations where two or more countries seek to tax the same profits. Recently enacted and...
The decision of the European Court of Justice in the Lexel AB case raises questions whether the valid business reason exception of...
The Amsterdam Appeal Court decision which addresses this question deals with the double tax treaty between France and the Netherlands of...
On 4 March 2021, the Dutch government presented a draft bill for comments by interested parties introducing fundamental changes to Dutch...
The Dutch Supreme Court decided in the Köln Aktienfonds Deka (KA DEKA) case that foreign investment funds are eligible for a refund of...
This is the last blog in a series on three documents published around the 2021 Dutch budget. It deals with a letter from the Dutch...
Following my blog on the (non-)amendment of the Dutch participation exemption for substance-less holding companies, this blog considers...
Somewhat hidden among the massive volume of tax legislation that came out as part of the 2021 Dutch budget on 15 September 2020, three...
The Dutch government published its 2021 budget on 15 September 2020. The tax measures were largely as anticipated and, where corporate...