International tax law

Part of our advisory work involves assessing and restructuring holding structures. We use the substance rules of DAC3 as a guideline for this. In each process, we identify the relevant levies, exemptions, anti-abuse frameworks and treaty rights (including withholding taxes). In practice, this involves not only the text of relevant legislation and treaties, but also enforcement priorities and the position of local authorities. We assist you in adopting the legal form required in the new country of establishment, including addressing potential issues and compliance requirements. In addition, we examine whether Dutch national tax provisions may be implemented under a treaty, such as the customary wage, the lucrative interest scheme, and interest on an excessive loan.

For most clients, speed is crucial. We are familiar with the legal and tax systems in many countries and know when a solicitor must be engaged, whether there is a waiting period (for example, for a merger or liquidation), and whether a transaction must be registered in advance. We anticipate these practical hurdles at an early stage, as they often lead to surprises and delays for companies. Where necessary, we work together with our international tax network. We offer you a realistic timeline with a single point of contact.