Our expertise
Experience is key! At NovioTax, we have extensive experience with internationally operating companies. Every company decision has tax consequences, and every country has its own tax system. By responding intelligently to differences in tax rules across countries, the tax burden can be reduced. We operate based on a moral compass; aggressive tax planning doesn’t align with our values. We offer proactive advice on ever-changing international tax legislation, bilateral investments, and transfer pricing disputes. Where necessary, we collaborate with our global tax network to deliver the best possible service to you.
What we do best
International tax law
For international companies, the tax landscape has become significantly more complex in a relatively short period. New rules at various levels (national, bilateral, and global), overlapping or conflicting provisions in treaties and varied interpretations complicate business decisions. It is crucial to determine the potential tax impact before making an investment or restructuring decision. Consider the application of the participation exemption, anti-hybrid measures, withholding taxes on dividends, interest, and royalties(in accordance with EU directives), and the interpretation of tax treaties and EU case law.
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.
Transfer pricing compliance
International companies must comply with transfer pricing rules and documentation requirements governing intragroup transactions. Our team closely monitors global transfer pricing (TP) case law and practice. For example, we analyse how foreign tax authorities approach comparability adjustments and in which cases the (internal) CUP method is applied. The latter can reduce clients’ need for benchmark studies.
Litigation and disputes
Transfer Pricing disputes are on the rise worldwide. Transfer Pricing (TP) is a key priority of tax authorities, multinationals, and the judiciary.
NovioTax is regularly called in by other advisors for (potential) TP corrections. Our approach is factual and proactive: we identify the relevant functions, risks, and assets in a timely manner (including through interviews), accurately delineate the intercompany transactions and select the most appropriate TP method for each transaction, preferably supported by one or two sanity checks. Economic reality is central to our analysis: who bears which risks, and where are the most important assets managed? Business relocations and reorganizations receive extra attention. We look beyond the documentation requirements: our focus is on the defensibility of the TP position.
Dividend WHT
NovioTax specialises in the Dividend Tax Act 1965 (DivBel) and the Withholding Tax Act 2021 (Wet BB 2021). Both regimes apply to outgoing payments (dividends, interest and royalties) to foreign beneficiaries. The rates vary from 15% (DivBel) to 25.8% (Wet BB 2021). Since 2024, the Wet BB 2021 has also applied to dividend payments to countries with low taxes and in cases of abuse. In practice, it revolves around the place of residence of the ultimate beneficiary (substance and beneficial ownership) and the question of which country has the right of taxation.
Innovation box
The innovation box regime encourages entrepreneurs to invest in innovative research by taxing profits from innovative activities (Research & Development, or R&D) at a reduced corporate income tax rate. An effective corporate income tax rate of 9% applies to the portion of the profit designated as R&D profit. In practice, it involves more than just calculations. Access requires at least a WBSO (Funding for Tax and Customs Administration) decision. For larger companies, a patent or other protection right is often also required.
International tax law
For international companies, the tax landscape has become significantly more complex in a relatively short period. New rules at various levels (national, bilateral, and global), overlapping or conflicting provisions in treaties and varied interpretations complicate business decisions. It is crucial to determine the potential tax impact before making an investment or restructuring decision. Consider the application of the participation exemption, anti-hybrid measures, withholding taxes on dividends, interest, and royalties(in accordance with EU directives), and the interpretation of tax treaties and EU case law.
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.
Transfer pricing compliance
International companies must comply with transfer pricing rules and documentation requirements governing intragroup transactions. Our team closely monitors global transfer pricing (TP) case law and practice. For example, we analyse how foreign tax authorities approach comparability adjustments and in which cases the (internal) CUP method is applied. The latter can reduce clients’ need for benchmark studies.
Litigation and disputes
Transfer Pricing disputes are on the rise worldwide. Transfer Pricing (TP) is a key priority of tax authorities, multinationals, and the judiciary.
NovioTax is regularly called in by other advisors for (potential) TP corrections. Our approach is factual and proactive: we identify the relevant functions, risks, and assets in a timely manner (including through interviews), accurately delineate the intercompany transactions and select the most appropriate TP method for each transaction, preferably supported by one or two sanity checks. Economic reality is central to our analysis: who bears which risks, and where are the most important assets managed? Business relocations and reorganizations receive extra attention. We look beyond the documentation requirements: our focus is on the defensibility of the TP position.
Dividend WHT
NovioTax specialises in the Dividend Tax Act 1965 (DivBel) and the Withholding Tax Act 2021 (Wet BB 2021). Both regimes apply to outgoing payments (dividends, interest and royalties) to foreign beneficiaries. The rates vary from 15% (DivBel) to 25.8% (Wet BB 2021). Since 2024, the Wet BB 2021 has also applied to dividend payments to countries with low taxes and in cases of abuse. In practice, it revolves around the place of residence of the ultimate beneficiary (substance and beneficial ownership) and the question of which country has the right of taxation.
Innovation box
The innovation box regime encourages entrepreneurs to invest in innovative research by taxing profits from innovative activities (Research & Development, or R&D) at a reduced corporate income tax rate. An effective corporate income tax rate of 9% applies to the portion of the profit designated as R&D profit. In practice, it involves more than just calculations. Access requires at least a WBSO (Funding for Tax and Customs Administration) decision. For larger companies, a patent or other protection right is often also required.
