Patrick Schrievers

Partner

Biography

Patrick has strong analytical skills and numerical insight. He likes to think outside the box. His approach is strategic and he advises with a long-term perspective. Patrick’s working style is characterised by honesty and transparency. He approaches all things with fairness, commitment and a touch of humour. His motto: ”We do it right or we don’t do it at all”.

  • Co-founder of NovioTax in 2016.
  • Advisor of choice for multinationals and listed institutions in the field of Dutch corporation tax and dividend tax, with a particular focus on transfer pricing (general audits, strategy determination, dispute resolution etc.)
  • Specialised in tax treaties, including income qualification, treaty compliance, the classification of partnerships, profit allocation to permanent establishments, etc.
  • Also has experience in handling legal proceedings relating to the allocation of the burden of proof and transfer pricing (TP) adjustments, as well as maintaining contact with tax authorities through Mutual Agreement Procedures (MAP) and other forms of dispute resolution.
  • Is the author of various tax publications (in Dutch and English).
  • Is a member of the International Fiscal Association (IFA).
  • Is a member of the NOB advisory board for offices with fewer than 15 members.
  • Is a member of the Dutch Association of Tax Advisers (NOB).
  • Worked at BDO and Loyens & Loeff.
  • Studied Business Economics and Fiscal Economics at Tilburg University.
  • Speaks and writes: Dutch and English.
 

Blogs written by Patrick

District Court confirms application of PSM in a client’s TP case

Authors: Gert-Jan Hop, Anneke Francissen, Patrick Schrievers, Lara Manraad, Neha Mohan
The District Court of North Holland issued a judgment in a Transfer Pricing case in which NovioTax represented the taxpayer, defending the application of the Profit Split Method, allocating 70% of the residual profits to the Netherlands and 30% to the PE jurisdiction, against the cost-plus approach (TNMM with 15% mark-up on a restricted cost base) proposed by the Dutch tax authorities. The case demonstrates the importance of comprehensive transfer pricing documentation in dispute resolution.

Implicit substance threshold embedded within the PE concept? Lessons from Luxembourg – Part III

Authors: Patrick Schrievers, Akshay Jahagirdar
This blog is Part 3 of a 3-part series analysing two Luxembourg cases related to (implicit) substance threshold for recognizing non-trading foreign branch offices as permanent establishments for availing exemptions from Luxembourg’s annual net wealth tax. This blog comprises our observations and key takeaways from the two cases discussed in Part 1 & 2.

Impact of legal ownership of expensive inventory on PLI – Part II

Authors: Patrick Schrievers
In this two-part blog, we analyse a Czech transfer pricing case dealing with a loss-making contract manufacturer and the legal ownership of high-value materials on arm’s length remuneration. Part I comprises a detailed analysis of the case, along with key observations. Part II comprises a summary of the case, followed by a (theoretical) analysis of the allocation of burden-of-proof under Dutch law, i.e., as if the Czech case were a Dutch case.

Implicit substance threshold embedded within the PE concept? Lessons from Luxembourg – Part II

Authors: Patrick Schrievers, Akshay Jahagirdar, Roya Rezaiee
This blog is Part 2 of a 3-part series analyzing two Luxembourg cases related to (implicit) substance threshold for recognizing non-trading foreign branch offices as permanent establishments for availing exemptions from Luxembourg’s annual net wealth tax. This blog outlines Case #2, concerning the recognition of a PE in the U.S., along with general observations and comments on the burden of proof.

Impact of legal ownership of expensive inventory on PLI – Part I

Authors: Patrick Schrievers, Neha Mohan
In this two-part blog, we analyse a Czech transfer pricing case dealing with a loss-making contract manufacturer and the legal ownership of high-value materials on arm’s length remuneration. Part I comprises a detailed analysis of the case, along with key observations. Part II comprises a summary of the case, followed by a (theoretical) analysis of the allocation of burden-of-proof under Dutch law, i.e., as if the Czech case were a Dutch case.

Implicit substance threshold embedded within the PE concept? Lessons from Luxembourg – Part I

Authors: Patrick Schrievers, Akshay Jahagirdar
This blog is Part 1 of a 3-part series analysing two Luxembourg cases related to (implicit) substance threshold for recognizing non-trading foreign branch offices as permanent establishments for availing exemptions from Luxembourg’s annual net wealth tax. This blog outlines Case #1, concerning the recognition of a PE in Malaysia, along with general observations and comments on the burden of proof.

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