International Tax Planning

Articles - Charlotte Tolman and Michael Molenaars examine the European Commission's proposed Unshell directive, which targets the misuse of shell companies, and its potential impact on Dutch holding structures.

Short Reads - On 22 December 2021 the European Commission (hereinafter: ‘EC’) presented two legislative proposals for EU directives, one to introduce a global minimum corporate tax rate and one to target EU shell entities. The key aspects of both proposals are discussed below.

Articles - Charlotte Tolman and Michael Molenaars will contribute periodically to Tax Notes International magazine. In their first article 'In Step With Stibbe' dated 29 March 2021, they discuss a topic which is highly relevant for Dutch corporate taxpayers involved in international intragroup transactions.

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.  

Articles - Charlotte Tolman and Michael Molenaars review Dutch efforts to enact a dividend withholding tax exit levy on corporations relocating from the Netherlands and examine how the most recent amendments affect the exit levy proposal.

Seminar - The NVP and Stibbe are organising the webinar 'Tax news for Private Equity and Venture Capital firms' on Thursday 2 December from 4 pm to 5.15 pm.

Articles - A tax team of Stibbe has contributed the Dutch chapter of Chambers Global Practice Guides Corporate Tax 2021.  

Articles - Johan Leonard and Roberto de Castro Mendonça authored the article titled "Taxation of Luxembourg cross-border workforce during the pandemic". The article is featured in the latest issue of the professional periodical "ACE".