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  • Article

    The Use Of Dutch Legal Entities In International Tax Reduction Strategies, Part II

    Hybrid entities are legal entities which in the country of the parent of the multinational group are seen as legal entities.
    NetherlandsTax
    Merlyn Holding BV
    Merlyn Holding BV
  • Article

    Shipping Update January 2024

    One of the conditions for applying the Dutch tonnage tax regime to a vessel that is owned, co-owned or held in bareboat charter and for which the taxpayer...
    NetherlandsTransport
    Loyens & Loeff
    Loyens & Loeff
Article

European Commission Publishes Far-Reaching Legislative Tax Proposals

On 22 December 2021, the European Commission released several legislative proposals that will impact corporate taxpayers.
European UnionTax
Loyens & Loeff
Loyens & Loeff
  • Article

    The Use of Hybrid Legal Entities in International Tax Reduction Strategies, Part III

    In WCR December 2009 we have shown how a Dutch "Cooperative Association" might be used in a hybrid form to a foreign tax payer’s advantage via international tax planning and in WCR March 2010 a similar article was devoted to the potentially hybrid Dutch limited liability companies NV, BV and SE.
    NetherlandsTax
    Merlyn Holding BV
    Merlyn Holding BV
  • Article

    A Dutch Tax Credit For Foreign Dividend W/H Tax, Even Though The Dividend Received Is Not Taxed In The Netherlands, Due To The Dutch Participation Exemption

    The Netherlands is under heavy attack, lately, because of its undisputed number one status in the world as treaty shopping jurisdiction.
    NetherlandsTax
    Merlyn Holding BV
    Merlyn Holding BV
  • Article

    The Use Of Dutch Hybrid Legal Entities In Group Structures Of Multinational Enterprises

    The Netherlands has always been one of the major locations which multinational enterprises have used to reduce the tax burden on their worldwide profits.
    NetherlandsTax
    Merlyn Holding BV
    Merlyn Holding BV
  • Article

    The Use Of Hybrid Legal Entities In Group Structures Of Multinational Enterprises, Part IV

    In several previous issues of WCR we have described how hybrid legal entities could be used to reduce the worldwide corporate income tax burden of a multinational group, as a matter of legal principle.
    NetherlandsTax
    Merlyn Holding BV
    Merlyn Holding BV
  • Article

    Impuesto A Los Servicios Digitales: ¿un Mal Necesario?

    Emine Constantin analiza los desafíos que la tecnología digital ha creado para el sistema tributario global y analiza cómo diferentes países están abordando esto a través de los impuestos...
    NetherlandsTax
    TMF Group BV
    TMF Group BV
  • Article

    US MNEs, How Will Pillar Two Impact Your Business?

    We recently hosted the webinar ‘The Implications of Pillar Two on US MNEs' as part of our Pillar Two webinar series.
    GlobalTax
    Loyens & Loeff
    Loyens & Loeff
  • Article

    "Check The Box" On China And The Netherlands Even If You Are Not A US Taxpayer! (The Use Of Hybrid Entities In International Tax Planning Structures Part V)

    I believe I have demonstrated how the use of hybrid entities in international tax planning has changed over time, from somewhat obscure in the past to fully accepted today, as a means to save oneself considerable tax amounts in a fully legal fashion.
    GlobalTax
    Merlyn Holding BV
    Merlyn Holding BV
  • Article

    ¿Dónde debe establecer su entidad en la UE?

    Descubra si estas jurisdicciones europeas clave son adecuadas para sus operaciones.
    European UnionFinance and Banking
    TMF Group BV
    TMF Group BV
  • Article

    Cooperative Associations To Be Brought Under The Dutch Dividend Tax Withholding Tax Act

    On September 20, 2011 the Dutch government announced a number of changes to its tax laws as part of the ‘’Budget 2012’’ proposals.
    NetherlandsTax
    Merlyn Holding BV
    Merlyn Holding BV
  • Article

    Independent Dutch Royalty Conduit Entities And Their Benefits For Multinational Enterprises

    One of the best guarded secrets of the Netherlands is its role in international tax planning via so-called conduit companies, which collect interest, dividends, capital gains and royalty payments for multinational enterprises worldwide.
    NetherlandsTax
    Merlyn Holding BV
    Merlyn Holding BV
  • Article

    Recent Developments With The Dutch Dividend Withholding Tax – A Major Bottleneck In International Tax Planning

    With The Recent Unfolding Of The Dutch Government's Tax Plans For 2012, On Budget Day (Traditionally The Third Tuesday In September), It Has Become Clear That The Netherlands Will Continue To Strive At Protection Of Its Dividend Withholding Tax.
    NetherlandsTax
    Merlyn Holding BV
    Merlyn Holding BV
  • Article

    Multilateral Convention Ratified By The Netherlands

    On March 5, 2019, the Upper House (Eerste Kamer) of the Dutch parliament approved the Multilateral Convention to implement tax treaty-related measures to combat base erosion and profit shifting.
    NetherlandsTax
    Dentons
    Dentons
  • Article

    Worldwide Developments In The Tax Concept Of Substance

    ‘Substance’ is a widely known tax concept, especially used in cross-border tax situations.
    NetherlandsTax
    Merlyn Holding BV
    Merlyn Holding BV
  • Article

    Dutch Tax Plan 2027

    The Dutch government has released its comprehensive tax plan for 2027, introducing significant changes across corporate income tax, dividend withholding tax, Pillar 2 implementation, employment taxation, and real estate transfer tax. Key measures include modifications to the participation exemption regime for hedging instruments, implementation of the OECD Side-by-Side Safe Harbour package for US-headed multinational groups, and new stock option schemes for startups and scale-ups designed to strengthen the
    NetherlandsTax
    A&O Shearman
    A&O Shearman
  • Article

    Corporate Tax Laws and Regulations Netherlands 2026

    There are 98 income tax treaties in force in the Netherlands. In addition, the Netherlands has signed several income tax treaties that are expected to enter into force in the future.
    NetherlandsTax
    BUREN
    BUREN
  • Showing 61–78 of 78 results

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