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Corporate Tax

We are Stibbe Corporate Tax specialists

Our technical and commercial expertise is perfectly placed to handle the most complex corporate tax transactions, disputes and projects for our clients.

Corporate Tax

Our aim is to work in close partnership with our clients, bringing tailor-made solutions, technical expertise and peace of mind to every complex domestic and international tax issue.

With this approach our corporate tax practice covers all areas of transactional and advisory work across the Benelux. This includes mergers and acquisitions, corporate reorganisations and restructuring, capital markets transactions as well as investment fund structuring, structured finance, transfer pricing and employee incentive plans. Of particular note is our extensive experience and knowledge in private equity transactions.

Furthermore, we bring technical and commercial expertise in dealing with tax authorities in obtaining an advance tax ruling and in mutual agreement procedures.

We have also developed a niche for private-public partnerships and other new forms of governmental or public entrepreneurship. The firm represents various authorities and businesses in this sector, with our team completing all the direct and indirect tax work in connection with all major projects undertaken by those entities.

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29.09.2020 NL law
Tax Alert: Public consultation additional source taxation on dividends to low tax jurisdictions

Short Reads - On 25 September 2020, the under minister of Finance released a draft legislative proposal open for public consultation until 23 October 2020. The draft legislative proposal includes a source taxation on profit distributions by Dutch companies to shareholders in low tax jurisdictions. It is proposed to enter into force as per 1 January 2024.

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15.07.2020 NL law
Emergency Act on Conditional Final Dividend Withholding Tax Levy submitted to Dutch parliament

Short Reads - On Friday 10 July 2020, a member of the Dutch opposition party Groenlinks has submitted an initiative legislative proposal for a Conditional Final Dividend Withholding Tax Levy Emergency Act (the 'Proposal') to Dutch parliament. The Proposal provides for a conditional final Dutch dividend withholding tax ('DWT') levy due in the event of certain cross-border reorganizations.

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28.04.2020 LU law
Chambers and Partners Real Estate Global Practice Guide 2020 - Luxembourg chapter

Articles - Claire-Marie Darnand, Victorien Hémery, Johan Léonard, Tom Storck, Benjamin Marthoz, Audrey Jarreton and François Bernard have all contributed to the 2020 Chambers and Partners Real Estate Global Practice Guide, providing the Luxembourg chapter. 

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24.09.2020 BE law
Stibbe hosts a webinar on dawn raids organised by IBJ/IJE

Seminar - On 24 September 2020, several Stibbe lawyers ​​​​​explain the rights and obligations of companies when confronted with announced or unannounced raids. What do to when, for example, tax authorities, the competition authorities, police services or a bailiff are at your doorstep?

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21.05.2020 NL law
Stibbe 'Netherlands Tax Firm of the Year'.

Inside Stibbe - The International Tax Review has chosen our Amsterdam Tax team as 'Netherlands Tax Firm of the Year'. This is Stibbe's fourth recognition in recent years, after receiving this distinguished title in 2015, 2017 and 2019.

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20.04.2020 NL law
Webinar on restructuring of corporate finance and distressed M&A

Seminar - The global COVID-19 crisis poses major challenges to many companies, their shareholders and financiers. On Thursday 23 April 2020 from 13.30 to 14.30 (CEST) Stibbe organizes a webinar on restructuring of corporate finance and distressed M&A. Stibbe partners Job van Hooff (Insolvency & Restructuring), Reinout de Boer (Tax) and Duco de Boer (Corporate | M&A) will discuss important issues and developments.

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03.04.2020 LU law
Bill of law on interest and royalties paid to non-cooperative jurisdictions

Short Reads - The Luxembourg Government proposes to introduce the non-deductibility of interest and royalties expenses of a Luxembourg taxpayer towards collective entities located in a blacklisted jurisdiction. This provision would be added through the amendment of article 168 of the Luxembourg Income Tax Law (LITL) through a bill of law that was introduced by the Government on 30 March.

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20.05.2020 NL law
Perpetual securities not considered equity for Dutch corporate income tax purposes

Short Reads - In a decision of Friday 15 May 2020, the Dutch Supreme Court confirmed that fixed-to-floating rate perpetual equity securities (“perpetual securities”) should not be considered a “participation loan” (deelnemerschapslening) for Dutch tax purposes. Under Dutch tax law, characterization of a debt instrument as a “participation loan” implies that such instrument is deemed equity for Dutch corporate income tax purposes. Characterization of the perpetual securities as a participation loan would have meant that the interest would have been regarded non-deductible dividend.

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18.04.2020 EU law
Report of advisory committee on taxation of multinationals in the Netherlands

Short Reads - On 5 June 2019, the Dutch Lower House of Parliament adopted a motion that called on the Government to initiate and set up a committee of experts (‘the Committee’) with the purpose to investigate measures that would make the taxation of profits of multinationals fairer, while the Netherlands would remain attractive for Dutch head offices. Last Wednesday (15 April 2020), the Dutch State Secretary of Finance sent the report of the Committee to the Dutch Lower House of Parliament.

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