140 results Stibbe contributes to Chambers Tax Controversy 2022 Stibbe’s Tax team contributed to the Dutch chapter of the Chambers and Partners Tax Controversy 2022. New double tax treaty concluded between Luxembourg and the United Kingdom: changes ahead Luxembourg and the United Kingdom signed a new Double Tax Treaty on 7 June 2022 which includes several changes that might have an effect on investments involving the two jurisdictions. Johan Léonard was interviewed by Paperjam Tax & Legal on the application of DAC6 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. Dutch Supreme Court: non-resident investment fund eligible for refund of Dutch dividend withholding tax 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. Johan Léonard and Roberto de Castro Mendonça write on taxation of crypto assets Stibbe Luxembourg's tax lawyers Johan Léonard and Roberto de Castro Mendonça authored the Luxembourg chapter of the multi-jurisdictional book titled "Taxation of Crypto Assets". OECD issues updated guidance on the impact of the COVID-19 crisis on tax treaties As noted in our Short Read of 7 April 2020, the Organisation for Economic Cooperation and Development (“OECD”) Secretariat issued preliminary guidance on several tax issues arising from the COVID-19 pandemic on 3 April 2020 (the “April Guidance”). Stibbe Luxembourg tax team writes on the taxation of cross-border workers in ACE Johan Leonard and Roberto de Castro Mendonça authored the article 'Taxation of Luxembourg cross-border workforce during the pandemic', which is featured in the latest issue of the professional periodical 'ACE'. Tax Alert: Public consultation additional source taxation on dividends to low tax jurisdictions 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 sharehold The Netherlands' Budget Day 2020: the impact of the Dutch 2021 Tax Package on international businesses In this Tax Alert we will summarize three recent tax developments that are relevant for international business with presence in the Netherlands. Introduction of dividend withholding tax in relation to low tax jurisdictions as per 2024 and update Dutch double tax treaty policy This Tax Alert will address two Dutch international tax policy proposals as included in letters that the Dutch State Secretary of Finance recently sent to the Dutch parliament on 29 May 2020. We note that the proposals are still subject to parliamentary d Restructuring & Insolvency in the Netherlands - 2020 What duties and potential liabilities should the directors/managers have regard to when managing a company in financial difficulties? Is there a specific point at which a company must enter a restructuring or insolvency process? Perpetual securities not considered equity for Dutch corporate income tax purposes In a decision of Friday 15 May 2020, the Dutch Supreme Court confirmed that fixed-to-floating rate perpetual equity securities (“perpetual securities”) should not be considered a “participation loan” (deelnemerschapslening) for Dutch tax purposes. Under D Public investment funds in the Netherlands - 2020 What does the fund registration process involve, e.g., what documents are required to be filed? What are the consequences for failing to register a fund that is required to be registered in Dutch jurisdiction? Or, What are the types of entities that can b Consultation on ATAD 2 (reverse hybrids) and amendment arm’s-length principle in the Netherlands As noted in our earlier 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. Emergency Act on Conditional Final Dividend Withholding Tax Levy submitted to Dutch parliament On Friday 10 July 2020, a member of the Dutch opposition party Groenlinks has submitted an initiative legislative proposal for a Conditional Final Dividend Withholding Tax Levy Emergency Act (the 'Proposal') to Dutch parliament. The Proposal provides for COVID-19 update and Guidelines published on the Dutch implementation of DAC6 The EU Mandatory Disclosure Directive (“DAC6”), introducing a reporting requirement for intermediaries and/or taxpayers of certain cross-border arrangements that are perceived to be aggressive, is effective as of 1 July in the Netherlands. By his letter o Chambers and Partners Real Estate Global Practice Guide 2020 - Luxembourg chapter Claire-Marie Darnand, Victorien Hémery, Johan Léonard, Tom Storck, Benjamin Marthoz, Audrey Jarreton and François Bernard have all contributed to the 2020 Chambers and Partners Real Estate Global Practice Guide, providing the Luxembourg chapter. Report of advisory committee on taxation of multinationals in the Netherlands The Dutch Lower House of Parliament adopted a motion that called on the Government to initiate and set up a committee of experts to explore fair multinational profit taxation. A report was submitted to Parliament last Wednesday (15 April 2020). Pagination Current page 1 Page 2 Page 3 Page 4 Next page
Stibbe contributes to Chambers Tax Controversy 2022 Stibbe’s Tax team contributed to the Dutch chapter of the Chambers and Partners Tax Controversy 2022.
New double tax treaty concluded between Luxembourg and the United Kingdom: changes ahead Luxembourg and the United Kingdom signed a new Double Tax Treaty on 7 June 2022 which includes several changes that might have an effect on investments involving the two jurisdictions.
Johan Léonard was interviewed by Paperjam Tax & Legal on the application of DAC6 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.
Dutch Supreme Court: non-resident investment fund eligible for refund of Dutch dividend withholding tax 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.
Johan Léonard and Roberto de Castro Mendonça write on taxation of crypto assets Stibbe Luxembourg's tax lawyers Johan Léonard and Roberto de Castro Mendonça authored the Luxembourg chapter of the multi-jurisdictional book titled "Taxation of Crypto Assets".
OECD issues updated guidance on the impact of the COVID-19 crisis on tax treaties As noted in our Short Read of 7 April 2020, the Organisation for Economic Cooperation and Development (“OECD”) Secretariat issued preliminary guidance on several tax issues arising from the COVID-19 pandemic on 3 April 2020 (the “April Guidance”).
Stibbe Luxembourg tax team writes on the taxation of cross-border workers in ACE Johan Leonard and Roberto de Castro Mendonça authored the article 'Taxation of Luxembourg cross-border workforce during the pandemic', which is featured in the latest issue of the professional periodical 'ACE'.
Tax Alert: Public consultation additional source taxation on dividends to low tax jurisdictions 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 sharehold
The Netherlands' Budget Day 2020: the impact of the Dutch 2021 Tax Package on international businesses In this Tax Alert we will summarize three recent tax developments that are relevant for international business with presence in the Netherlands.
Introduction of dividend withholding tax in relation to low tax jurisdictions as per 2024 and update Dutch double tax treaty policy This Tax Alert will address two Dutch international tax policy proposals as included in letters that the Dutch State Secretary of Finance recently sent to the Dutch parliament on 29 May 2020. We note that the proposals are still subject to parliamentary d
Restructuring & Insolvency in the Netherlands - 2020 What duties and potential liabilities should the directors/managers have regard to when managing a company in financial difficulties? Is there a specific point at which a company must enter a restructuring or insolvency process?
Perpetual securities not considered equity for Dutch corporate income tax purposes In a decision of Friday 15 May 2020, the Dutch Supreme Court confirmed that fixed-to-floating rate perpetual equity securities (“perpetual securities”) should not be considered a “participation loan” (deelnemerschapslening) for Dutch tax purposes. Under D
Public investment funds in the Netherlands - 2020 What does the fund registration process involve, e.g., what documents are required to be filed? What are the consequences for failing to register a fund that is required to be registered in Dutch jurisdiction? Or, What are the types of entities that can b
Consultation on ATAD 2 (reverse hybrids) and amendment arm’s-length principle in the Netherlands As noted in our earlier 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.
Emergency Act on Conditional Final Dividend Withholding Tax Levy submitted to Dutch parliament On Friday 10 July 2020, a member of the Dutch opposition party Groenlinks has submitted an initiative legislative proposal for a Conditional Final Dividend Withholding Tax Levy Emergency Act (the 'Proposal') to Dutch parliament. The Proposal provides for
COVID-19 update and Guidelines published on the Dutch implementation of DAC6 The EU Mandatory Disclosure Directive (“DAC6”), introducing a reporting requirement for intermediaries and/or taxpayers of certain cross-border arrangements that are perceived to be aggressive, is effective as of 1 July in the Netherlands. By his letter o
Chambers and Partners Real Estate Global Practice Guide 2020 - Luxembourg chapter Claire-Marie Darnand, Victorien Hémery, Johan Léonard, Tom Storck, Benjamin Marthoz, Audrey Jarreton and François Bernard have all contributed to the 2020 Chambers and Partners Real Estate Global Practice Guide, providing the Luxembourg chapter.
Report of advisory committee on taxation of multinationals in the Netherlands The Dutch Lower House of Parliament adopted a motion that called on the Government to initiate and set up a committee of experts to explore fair multinational profit taxation. A report was submitted to Parliament last Wednesday (15 April 2020).