About Patrick T.F. Schrievers

Patrick T.F. Schrievers concentrates his practice in the area of tax advisory for transnational business operations, with emphasis on intercompany transactions. Patrick represents companies in matters involving the Dutch Tax Administration and counsels corporate clients on transfer pricing issues and worldwide reorganizations. He advises foreign private clients on structuring investments in the Netherlands.

He is a frequent speaker at international conferences and is regularly asked to assist with transfer pricing dispute resolution (including mutual agreement procedures) and audits. He is also frequently involved in drafting and assessing transfer pricing documentation and country-by-country reporting. In addition to his involvement with the firm Patrick acts as (part-time) inhouse tax and finance advisor of multinational groups. In this function he advises on tax aspects of (domestic and cross-border) transactions and (re)structuring of investments.

Patrick graduated in Business economy and Tax economy, both from Tiburg University. He is a member of the Netherlands Association of Tax Advisers (NOB), the International Fiscal Association (IFA) and author of a series of papers about tax aspects of cross-border investment structuring. Before joining NovioTax he was a senior associate at Loyens & Loeff. Patrick joined NovioTax at the end of 2016 as a partner. Patrick serves as the editor of the monthly papers and blogs.

Internal Publications

• Kuwait – South African Protocol affects the lower WHT on Dividends between South Africa and the Netherlands (June 2021)
• Russia - Netherlands DTAA terminated by January 1 2022, will it be replaced? (May 2021)
• Participation exemption regimes could cost WHT reliefs under EU Parent-Subsidiary Directive and DTAAs (January 2021)
• Interrelating treaties lower the WHT on Dividends between South Africa and the Netherlands (December 2019)
• CJEU cases on beneficial ownership and treaty abuse – case overview
• CJEU rules in Danish cases on beneficial ownership and treaty abuse
• The potential impact of a Brexit on Tax
• De laatste transfer pricing trends in Nederland (EN)
• The latest transfer pricing trends in the Netherlands
• Innovatiebox-rulings, to rule or not to rule?
• Belastingplan 2019 – een selectie
• De Belastingdienst kan geen ijzer met handen breken bij een afdoende transfer pricing documentatie
• This close to disclose?
• This close to disclose? (EN)
• German Tax Court utilizes third party bank loan to benchmark shareholder loans
• BREXIT – what actions are required for companies doing business with and within the UK
• New US tax reform
• Introduction of a dividend withholding tax exemption
• Amended substance requirements
• Fiscal measures in German coalition agreement
• Summary of international and Dutch tax developments in 2017
• The Hague decision on Netherlands non-resident taks
• Transfer of valuable intangibles
• Adjustments Luxembourg Transfer Pricing Rules
• Changes to the Netherlands Innovation Box: limitation on IP assets
• Transfer pricing aspects of centralized purchasing
• Changes to the Netherlands Innovation Box: Profit Allocation
• Dutch legislative amendments per 1 January 2018 aim to strengthen tax climate whilst tackling tax avoidance
• Maintaining a long-term European joint venture
• Investing in the Netherlands via the UAE
• Italian Supreme Court issues guidance on beneficial ownership conditions for pure holding companies
• A wake-up call for companies with commissionaire and similar structures