Corporate income tax
The 1969 Corporation Tax Act is central to our services. We translate complex regulations into clear choices. We are often asked by other advisors for a second opinion.
Within this broad playing field, we advise on a wide range of issues. These include tax entity issues, such as assessing the adverse consequences of a break-up of/separation from a tax entity, profit splitting issues, offsetting of losses carried forward, the treatment of intercompany transactions, and the interaction with interest deduction restrictions.
Analysis and optimisation of corporate income tax positions
We assess the application of the participation exemption and the object exemption, including the conditions under which an exemption can be obtained and the amount for which it can be claimed. We classify foreign entities as transparent or non-transparent, examine whether business combinations and legal demergers qualify for a facility, and assess the effect of interest deduction restrictions (and their impact on internal loans). We also advise on the prohibition on deducting costs associated with the purchase and sale of participations.
In addition, we offer specialised real estate advice as part of our tax services. We assess whether a demerger or merger of a real estate company can be facilitated for corporation tax purposes and ensure the correct application of transfer tax.
NovioTax has extensive experience in arranging innovation box agreements with the Dutch tax authorities: from providing convincing substantiation to the tax authorities (preliminary consultation/ruling) to reviewing and refining existing agreements. Our Transfer Pricing expertise is a strong asset in this regard. Correct profit allocation to R&D is usually only possible when the remuneration for functions such as sales, production and distribution has already been determined on an arm’s length basis. This leaves exactly that part of the profit that can be placed in the innovation Box for tax purposes. We model P&L and tax effects, evaluate intangible assets (if necessary), and ensure consistency between innovation Box agreements and TP documentation (master/local file).
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