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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Consultation on ATAD 2 (reverse hybrids) and amendment arm’s-length principle in the Netherlands

Short Reads - As noted in our earlier Tax Alerts (see our Tax Alerts of March 2017 and July 2019), the EU Anti-Tax Avoidance Directive 2 ("ATAD 2") provides for minimum standards to neutralize hybrid mismatches and came into effect in the Netherlands as of 1 January 2020. However, as an exception, the rule that targets so-called “reverse-hybrid” mismatches will become effective only as of 1 January 2022.  

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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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