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  • Article

    Dutch Tax Plans 2025: New Group Concept Conditional Withholding Tax – New York Office Snippet

    Loyens & 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 StatesTax
    Loyens & Loeff
    Loyens & Loeff
  • Article

    EU Tax Directives #6 Repeal Of 3 Proposed EU Tax Directives - New York Office Snippet

    Loyens & 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 StatesTax
    Loyens & Loeff
    Loyens & Loeff
  • Article

    Excluded Entities Under Pillar Two – New York Office Snippet

    Loyens & 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 StatesTax
    Loyens & Loeff
    Loyens & Loeff
  • Article

    Pillar Two: Asset Transfers Under Pillar Two – New York Office Snippet

    For 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 StatesTax
    Loyens & Loeff
    Loyens & Loeff
  • Article

    The European Council Formally Endorsed The CSDDD

    After intensive negotiations on the (final) text, the long-expected CSDDD has now formally endorsed by the European Council The CSDDD establishes on the one hand a corporate...
    European UnionEnvironment
    Loyens & Loeff
    Loyens & Loeff
  • Article

    The EU AML Package And Implications For The Dutch Draft Action Plan On Money Laundering

    On 24 April 2024, the European Parliament agreed to an anti-money laundering package (EU AML package). A week earlier, the Dutch Finance minister wrote to the House of Representatives about the potential...
    European UnionGovernment, Public Sector
    Loyens & Loeff
    Loyens & Loeff
  • Article

    Introduction To Luxembourg As A Hub For US Private Fund Managers Targeting Private Wealth – New York Office Snippet

    EU Member States (EUMS), but also most other states, impose restrictions on selling funds that invest in the private markets to investors who invest their private wealth.
    GlobalFinance and Banking
    Loyens & Loeff
    Loyens & Loeff
  • Article

    US Sponsors Launching A Luxembourg Fund: How To Organize The Fee Flow? – New York Office Snippet

    US fund sponsors who raise capital in the EU will encounter that some EU investors prefer to commit to an EU fund vehicle rather than a non-EU vehicle. An EU fund vehicle is typically organized...
    GlobalFinance and Banking
    Loyens & Loeff
    Loyens & Loeff
  • Article

    We Advised The Ad-hoc Group Of Noteholders In The Financial Restructuring Of The Frigoglass Group

    On 27 April 2023, the recapitalization and financial restructuring of the Frigoglass group was successfully completed, which was implemented by way of a consensual...
    LuxembourgInsolvency/Bankruptcy/Re-Structuring
    Loyens & Loeff
    Loyens & Loeff
  • Article

    Tax Attention Points For Luxembourg SMAs - New York Office Snippet

    To accommodate EU capital raising, US fund managers (USFM) usually set up their investor-facing fund vehicle in Luxembourg, typically in the form of a Luxembourg special limited partnership (SCSp).
    LuxembourgTax
    Loyens & Loeff
    Loyens & Loeff
  • Article

    Transfer Pricing Guidelines

    With this alert we would like to update you on the latest Transfer Pricing developments.
    LuxembourgTax
    Loyens & Loeff
    Loyens & Loeff
  • Article

    Dutch Senate Approves The Act On The Abolition Of Pledge Prohibitions

    Under the current legal framework in the Netherlands, Dutch law governed receivables may be incapable of being assigned or pledged.
    NetherlandsFinance and Banking
    Loyens & Loeff
    Loyens & Loeff
  • Article

    Medical Devices Regulation (MDR) Entered Into Effect

    On May 26, 2021 the Medical Devices Regulation (MDR) entered into effect after a four-year transitional period.
    NetherlandsFood, Drugs, Healthcare, Life Sciences
    Loyens & Loeff
    Loyens & Loeff
  • Article

    Clarity For The Construction Sector: UAC 2012 Aligned With The Dutch Quality Assurance Act

    On 26 February 2025, the Ministry of Housing and Spatial Planning published a revised version of the UAC 2012, removing sections 1 and 2 of paragraph 12...
    NetherlandsReal Estate and Construction
    Loyens & Loeff
    Loyens & Loeff
  • Article

    Legislative Proposal On Additional Withholding Tax On Dividends To Low-taxed Jurisdictions As Of 1 January 2024

    On 25 March 2021, the Dutch government published the legislative proposal to introduce an additional withholding tax (Additional WHT) on intragroup dividends to low-taxed jurisdictions as of 1 January 2024 (the Proposal).
    NetherlandsTax
    Loyens & Loeff
    Loyens & Loeff
  • Article

    Political Agreement To Amend The 2022 Tax Plan: Increase Headline Rate Corporate Income Tax And Tightening Of The Earnings Stripping Rules

    On 21 September 2021, the Dutch Ministry of Finance submitted the 2022 Dutch Budget to parliament, including the Tax Plan 2022.
    NetherlandsTax
    Loyens & Loeff
    Loyens & Loeff
  • Article

    The Automotive Supply Chain's Tax Year

    European automotive suppliers are preparing the fiscal year 2025 corporate income tax returns against a sector that no longer matches the assumptions underlying their existing tax positions.
    NetherlandsTax
    Loyens & Loeff
    Loyens & Loeff
  • Article

    The Hague Convention On The Choice Of Court Agreements – Entry Into Force In Switzerland

    The Hague Convention of 30 June 2005 on the Choice of Court Agreements (Hague Convention) has entered into force in Switzerland on 1 January 2025.
    SwitzerlandFinance and Banking
    Loyens & Loeff
    Loyens & Loeff
  • Article

    Restructuring Options In Switzerland: Pre-Packs

    Pre-packs, known as an effective restructuring measure from other jurisdictions, are also permissible in Switzerland.
    SwitzerlandInsolvency/Bankruptcy/Re-Structuring
    Loyens & Loeff
    Loyens & Loeff
  • Article

    Switzerland As A Premier Global Commodities Trading Hub

    Switzerland's position as a leading global commodities trading hub is reinforced by competitive cantonal tax rates, efficient infrastructure, and a favourable regulatory environment.
    SwitzerlandTax
    Loyens & Loeff
    Loyens & Loeff

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