International Tax Planning

Inside Stibbe - For the fifth time, Stibbe has been named ‘Netherlands Tax Firm of the Year’ by International Tax Review.

Short Reads - A legislative proposal regarding a conditional withholding tax on dividends (if adopted: effective as of 1 January 2024) (Wetsvoorstel bronbelasting dividenden) was submitted to Dutch parliament on Thursday 25 March 2021.  

Articles - Stibbe's Luxembourg tax partner Johan Léonard was amongst the few experts selected by Luxembourg's leading business publication Paperjam to discuss the implications of the DAC6 Directive in Luxembourg and throughout Europe.

Articles - On 6 October 2020, the European Union list of non-cooperative jurisdictions (the “EU List") was updated. The changes have an impact on bill of law nº 7547, providing that, as from 1 January 2021, interest or royalties, accrued or paid, should no longer be deductible for tax purposes when the beneficiary is a related enterprise established in a country included in the EU List.

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.  

Short Reads - On 23 October 2020, the Dutch Supreme Court ruled that a non-resident UCITS fund is eligible for a refund of Dutch dividend withholding tax with respect to its investments in the Netherlands if strict criteria are met.

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?