ArticleResidential Rental Price Indexation Clauses For Liberalized Units Are UpheldOn Friday, 29 November 2024, the Supreme Court provided clarity on what type of rental price indexations for liberalized housing are permitted.NetherlandsReal Estate and ConstructionLoyens & Loeff
ArticleAcquisition Self-Storage Company Taxed With RETT?Whether real estate transfer tax is due on the acquisition of shares in a private limited company (BV) with a 'self-storage' business remains unclear. NetherlandsTaxLoyens & Loeff
ArticleDutch Tax Authorities: Model Agreement Unrestricted Substitution Will Lose Its ValidityDo you hire self-employed individuals with an agreement based on the Model agreement "unrestricted substitution"?NetherlandsTaxLoyens & Loeff
ArticleForecast Dutch Budget Day 2024On Budget Day 2024, Tuesday 17 September 2024, the Dutch government will present its budget for 2025 alongside its envisaged tax changes...NetherlandsTaxLoyens & Loeff
ArticleOECD's Plans For Global Minimum Taxation: The Next StepsThe OECD seeks consensus by the end of 2020 on how to ensure all profits of multinational groups are subject to a (yet to be determined) worldwide minimum level of taxation. NetherlandsTaxLoyens & Loeff
ArticlePillar Two: Flow-Through Entities (Part 1): Tax Transparent Entities – New York Office SnippetP2 applies to all entities that form part of a multinational group with annual revenues of at least €750M. This also includes entities (incl. partnerships) that are treated as transparent for local tax purposes.NetherlandsTaxLoyens & Loeff
ArticlePillar Two: Flow-Through Entities (Part 2): Reverse Hybrids – New York Office SnippetP2 applies to all entities that form part of a multinational group with annual revenues of at least €750M. This includes entities that are treated as transparent for local tax purposes.NetherlandsTaxLoyens & Loeff
ArticleVAT Fixed Establishment Non-Existing Without StaffThe European Court of Justice (ECJ) ruled in the highly anticipated Titanium case that own staff is required for a ‘fixed establishment' for VAT. In the case at hand, real property used...NetherlandsTaxLoyens & Loeff
ArticleVAT Treatment Of Fuel Cards Further ClarifiedIn Europe it has been unclear for years whether card and lease companies are entitled to recover VAT on fuel costs. Also in the Netherlands, the VAT treatment of fuel costs is an occasional topic of discussion.NetherlandsTaxLoyens & Loeff
ArticleCrypto-Asset Services Providers Can Apply For A Licence With The AFM As Of 22 AprilFrom 22 April 2024, crypto-asset service providers (CASPs) have the option to apply for a licence with the Dutch Authority for the Financial Markets (AFM).NetherlandsTechnologyLoyens & Loeff
ArticleClaw Back Rights Under Swiss LawIf bankruptcy proceedings are commenced against a debtor or if a debtor enters into a court-approved composition agreement with an assignment of all of its assets, transactions executed by the debtor...SwitzerlandInsolvency/Bankruptcy/Re-StructuringLoyens & Loeff
ArticleThe Recognition Of Foreign Bankruptcy Decrees In SwitzerlandA foreign bankruptcy or insolvency decree only has effect on the debtor's Swiss assets if it is formally recognised by a Swiss court.SwitzerlandInsolvency/Bankruptcy/Re-StructuringLoyens & Loeff
Article2024 Swiss Safe Harbour Interest Rates For Intra-Group Loans – EUR And GBP Rate Decreased, USD Rate IncreasedOn 29 and 30 January 2024, the Swiss Federal Tax Administration (SFTA) published the safe harbour interest rates for the year 2024. The rates apply to intra-group loans denominated in Swiss Francs and foreign currencies as of 1 January 2024.SwitzerlandTaxLoyens & Loeff
ArticleSwiss Federal Tax Administration Publishes Website With Q&A On Selected TP TopicsAfter publishing a summary on transfer pricing rules in Switzerland (TP Paper), the SFTA has now published a website notably including a rather extensive Q&A on selected Swiss transfer pricing topics.SwitzerlandTaxLoyens & Loeff
ArticleFinIA Reform: New Licences For Payment And Crypto-institutionsOn 22 October 2025, the Swiss Federal Council opened a consultation on a proposed amendment to the Financial Institutions Act (the FinIA). SwitzerlandTechnologyLoyens & Loeff
ArticleHow Can US Fund Managers Tap Into The Swiss Private Wealth Market? – New York Office SnippetSwiss fund marketing rules differ significantly from EU regimes, offering US fund managers flexibility in pre-marketing activities while imposing specific registration requirements for formal marketing...United StatesFinance and BankingLoyens & Loeff
ArticleDutch Tax Plans 2025: New Group Concept Conditional Withholding Tax – New York Office SnippetLoyens & Loeff NY regularly posts 'Snippets' on EU tax and legal topics. This Snippet describes proposed changes to the Dutch conditional withholding tax (𝐂𝐖𝐓) rules under the 2025 Dutch tax plans.United StatesTaxLoyens & Loeff
ArticleEU Tax Directives #6 Repeal Of 3 Proposed EU Tax Directives - New York Office SnippetLoyens & Loeff New York regularly posts ‘Snippets' on a range of EU tax and legal topics. Earlier this calendar year, our ‘EU Tax Directives Series' offered practical, concise summaries of key EU tax directives...United StatesTaxLoyens & Loeff
ArticleExcluded Entities Under Pillar Two – New York Office SnippetLoyens & Loeff New York regularly posts ‘Snippets' on a range of EU tax and legal topics. This Snippet discusses excluded entities under Pillar Two (𝐏𝟐) in EU fund structures set up by US fund managers.United StatesTaxLoyens & Loeff
ArticlePillar Two: Asset Transfers Under Pillar Two – New York Office SnippetFor P2, asset transfers must generally occur against market value (‘MV'). I.e., the transferring entity (‘TE') generally recognizes gain or loss on the transfer and the acquiring entity...United StatesTaxLoyens & Loeff