International Tax Planning

Articles - Charlotte Tolman and Michael Molenaars examine the tax governance code as recently presented by VNO-NCW and which has been endorsed by 40+ multinationals.

Articles - Met regelmaat verschijnt nieuwe rechtspraak over de informatiebeschikking van art. 52a AWR. Deze regeling roept na de inwerkingtreding in 2011 nog steeds vragen op, waardoor vele kwesties voor de Hoge Raad zijn gekomen. Tirza Cramwinckel en Mieke Lavreysen houden in het Tijdschrift voor Formeel Belastingrecht de ontwikkelingen rondom deze regeling tegen het licht.

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 - 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.