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The Dutch tax authorities published a new Knowledge Group (KG) position clarifying that the Dutch transfer pricing mismatch rules do not apply when a foreign regime that effectively functions as an objective exemption applies to the transfer of a participation.

The Netherlands currently applies the ‘similarity approach' to classify foreign entities. In short, this approach means that one looks at the most similar Dutch equivalent of the foreign...

The ‘M-GmbH' ruling of the European Court of Justice (‘ECJ'), issued on 15 April 2021, paves the way for a broader application of the VAT group than most EU countries currently apply.

The OECD's proposed revisions to Chapter VII of the Transfer Pricing Guidelines represent the most extensive rewrite of intra-group services guidance in years, introducing new requirements for accurate delineation, expanded benefit testing, and dedicated documentation standards. Loyens & Loeff's Transfer Pricing team has submitted detailed comments assessing whether these changes reduce compliance burdens or risk increasing double taxation for multinational enterprises.

As we start the new year, we have prepared an overview of the key Dutch and international tax developments impacting the shipping and offshore services industry.

As of 1 January 2025, the enforcement moratorium (handhavingsmoratorium) under the Employment Relationships Deregulation Act (Wet DBA) (DBA Act) will be terminated.

In a meeting on 6 November 2019, the Federal Council decided that the Financial Services Act and the Financial Institutions Act, together with the corresponding ordinances, will enter into force on 1 January 2020.

Swiss law generally maintains a strict separation between a company's assets and those of its shareholders, but courts may exceptionally disregard this principle when it constitutes an abuse of rights. This analysis explores the legal framework and practical requirements for both piercing and reverse piercing the corporate veil in Switzerland, with particular emphasis on how these doctrines apply in debt enforcement and attachment proceedings.

The referendum period for extending the Swiss tax loss carryforward period expired on 17 April 2026 without a referendum being called. As a result, the corresponding legislative amendments to the Federal Direct Tax...

The OECD/G20 global minimum tax (Pillar 2) has fundamentally altered how tax-based business location incentives function for multinational enterprises. The January 2026 Administrative Guidance introduces the "Substance-based Tax Incentive Safe Harbour" framework, creating new opportunities through Qualified Tax Incentives (QTIs) that may preserve economic benefits of certain tax incentives under Pillar 2 rules, though with important limitations tied to substance requirements.

On 1 July 2025, the Hague Judgments Convention entered into force in the UK, offering a clearer and more consistent framework for the recognition and enforcement of civil and commercial judgments between contracting states.

A significant part of capital raised by Dutch emerging companies comes from US investors who are often unfamiliar with the legal documents and closing process of an investment round in the Netherlands.

On 26 June 2025, the United States (U.S.) Treasury announced an agreement with the other G7 countries regarding the application of the OECD Pillar Two rules to U.S.-parented multinational enterprises (U.S. MNEs).

An act was approved amending the transitional provisions for workers employed before 1 January 2014. These transitional provisions provide, inter alia, for a calculation of the notice period in two parts...

Our Transfer Pricing colleagues have contributed to a special issue of the International Transfer Pricing Journal on the DEMPE concept in domestic Transfer Pricing practice.

On 12 May 2021, the General Court of the EU upheld the European Commission decision of June 2018 finding that Luxembourg had granted unlawful State aid to ENGIE by means of various tax rulings.

The Netherlands has unique rules when it comes to the classification of foreign entities and limited partnerships ("LPs") for tax purposes. LPs are only considered transparent for Dutch...