International Tax Planning

We are Stibbe International Tax Planning specialists

Our teams complete a substantial amount of international tax and tax planning work, providing solutions for clients in jurisdictions around the world.

International Tax Planning

We understand the challenges our global clients face in complex international tax transactions, from both a legal, tax and practical perspective. It’s why we provide to-the-point and effective advice, whenever it’s needed.

Our offices in Amsterdam, Brussels, Luxembourg, Dubai, London and New York are complemented by a global network of firms recognised as leaders in their respective jurisdictions. These relationships enable us to assemble a tailor-made, integrated team of lawyers that works seamlessly with the best tax expertise and contacts around the globe. 

The breadth of our accumulative knowledge in this field is extensive with almost all our tax lawyers possessing foreign qualifications, or practical work experience abroad including the US and the UK.

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Related news

11.06.2018 NL law
Legislative proposal on changes to the Dutch CIT fiscal unity made public

Short Reads - On 22 February 2018 the European Court of Justice ('ECJ') decided on two cases (C-398/16 and C-399/16), which are relevant for purposes of the 'per-element-approach' concerning the Dutch corporate income tax ('CIT') fiscal unity regime. To mitigate the (negative financial) impact of the decisions of the ECJ, the Dutch State Secretary announced last year that new legislation (with retroactive effect to 25 October 2017) will be introduced to amend the CIT fiscal unity regime.

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12.09.2018
Nadere uitleg van de Hoge Raad over 'op de zaak betrekking hebbende stukken'

Short Reads - De Hoge Raad heeft in drie belangwekkende arresten van 17 augustus 2018 een nadere uitleg gegeven over het verstrekken van op de zaak betrekking hebbende stukken. De drie arresten gaan over belastingzaken maar zij zijn relevant voor het hele bestuursrecht. In dit blogbericht gaan wij in op deze arresten en de betekenis daarvan voor de praktijk. Wij zullen in het bijzonder stilstaan bij de wijze waarop de Hoge Raad oordeelt over het verstrekken van gegevens bij geautomatiseerde besluitvorming.

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09.05.2018
Proposed EU Directive to help companies move across borders

Short Reads - On 25 April 2018 the European Commission proposed a new directive, amending the EU Directive 2017/1132 on company law. The proposed rules should support companies in moving from one EU country to another, i.e. cross-border mergers, divisions or conversions. However, the proposed rules for cross-border divisions and conversions will also require companies to get prior consent from a competent national authority before moving. Who will act as such authority is not clear yet.

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22.02.2018 NL law
ECJ ruling on Dutch CIT Fiscal Unity prompts legislative action

Short Reads - In this Tax Alert we will address the anxiously awaited ruling of the European Court of Justice ("ECJ") on the joined cases C-398/16 and C-399/16. This judgement deals with the question whether EU law obliges the Netherlands to let taxpayers cherry pick benefits from the fiscal unity regime. We also mention the announcement of the Dutch Ministry of Finance to improve the rules for obtaining tax rulings in the Netherlands.

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07.08.2018 NL law
Dutch international taxation - current developments

Short Reads - The global debate on alleged aggressive international tax planning initiated by the G20/OECD and the EU, is an important driver of the current developments in the field of international taxation. The following is a high level summary of certain developments relevant for the Netherlands:

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03.07.2018 NL law
Abolishment of tax deductibility of coupon payments on AT-1 capital instruments announced per 1 January 2019

Short Reads - On Friday 29 June 2018, the Dutch government made public its intention to abolish article 29a Dutch corporate income tax act ('DCITA'), per 1 January 2019. As a result of the abolishment of this provision, coupon payments on so-called additional-tier 1 ('AT-1') capital instruments made by banks and insurance companies will no longer be tax deductible. The amendment of the DCITA, which is aimed to be included in the tax package for 2019, will apply to coupon payments made after 1 January 2019, irrespective whether it concerns new or already existing AT-1 instruments.  

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27.02.2018 NL law
Further guidance on Dutch ATAD implementation and measures against letterbox companies

Short Reads - Further to the policy plans published by the Dutch government in October 2017, the Dutch State Secretary of Finance published on February 23, 2018 a Letter (the "Letter") containing further details on certain aspects of the Dutch government's two way approach of enhancing the investment climate in the Netherlands.

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