Our multi-disciplinary team provides responsive and practical support, ensuring your ability to adapt in today’s ever-changing environment. Together with our team, made up of professionals brought together from our key practice groups, you will reap the benefit of our full range of services and knowledge. In other words, we are your one-stopshop for all legal and tax solutions. Our global reach also enables us to stay one step ahead of ever-evolving technologies, international tax developments and regulations affecting your business.

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Implementing Pillar One & Pillar Two

Implementing Pillar One & Pillar Two

Building upon work conducted for several years on how to adapt the international tax rules to an increasingly digitalised economy, the OECD/G20 Inclusive Framework proposes a two-pillar overhaul of the existing system as from 2023/2024. While the main policy features are agreed, detailed model rules and draft multilateral conventions are due to be released over 2022.

Tax directors and their teams can already model the impact, prepare for the additional tax compliance burden and assess opportunities for manageable restructurings to mitigate the increased complexity.

Substance & Tax Law

Substance & Tax Law

In recent years tax authorities have placed more emphasis on combatting the use of abusive and aggressive tax structures by companies operating across borders, to ensure fair taxation. The EU and OECD have provided tax authorities with various instruments such as the Anti-Tax Avoidance Directive (ATAD) and the Multilateral Instrument. The judgements handed down by the CJEU on the Danish cases have also set an important precedent.

However, since entities with no minimal substance and economic activity are supposedly still used for improper tax purposes, the European Commission recently issued a new proposal (ATAD 3). It is highly recommended that taxpayers already assess the possible impact of the proposal and consider opportunities for strengthening their local footprint and/or restructuring.

30-11-2023

In this update, our specialists inform you about relevant current tax developments and trends in the Netherlands, Belgium, Luxembourg and Switzerland that have an impact on MNEs.

How we can help

Agreements

Examples of our work include agency and commissionaire agreements, licence agreements, ICT contracts, R&D agreements and lease agreements. We work with restructuring agreements, data protection, supply of products & services, franchise agreements and exclusive & selective distribution agreements. We also prepare guidelines on pre-contractual information duties.

Tax

Our market-leading tax practice provides pragmatic, tailored support, bearing in mind the importance of tax position confidence and the need for transparency

Transactions

For cross-border transactions, you can rely on our expert solutions. You can  also rely on us for tax and legal advice on mergers & acquisitions (M&A), private equity, equity capital markets, venture capital, corporate governance and more.

Capital markets

Allow us to assist you in finding innovative ways to navigate the complex capital markets environment and unlock opportunities to achieve your objectives. Our Capital Markets team are region leaders who act for both issuers and the buy- and sell-side. By combining transactional skills, tax knowledge and financial regulatory expertise, we are able to handle complex capital markets transactions.

Internal organisation

We can work with you on employment, incentives (including tax implications), compensation, transfer-pricing in intra-group agreements, corporate housekeeping, corporate finance, real estate and agreements with third party service providers.

Compliance & risk management

We provide compliance support for fair trade practice regulations, European competition rules and merger control. We can also work with you to manage data and privacy protection, parallel imports, product liability & recalls, market practices, direct taxes and advantages in kind granted to personnel. Our team provides support on tax incentives, assistance in tax ruling procedures, VAT and car tax issues, customs and international trade issuesas well as environmental permits.

Dispute resolution We offer advice and support on the protection, exploitation and enforcement of intellectual property rights. We are experts in tax audits, tax litigation, termination of employment and conflicts relating to incentives and working time. We also cover issues of termination of commercial agreements, contractual non-compliance, settlement agreements and arbitration & mediation.

Financing solutions are multiplying and the legal implications relating to financial products are becoming more complex.
The world of capital markets is characterised by rapid change, increased regulation and innovation.

Large and medium-sized companies often encounter competition law and other types of governmental regulation in many aspects of their business. To succeed in the modern world, companies need to navi

As an international organisation, you face many challenges, from ever-changing regulations to complex cross-border transactions and beyond.
Using a unique integrated and solution-driven approach, we help guide you through these issues. We cover the full spectrum of employment law - pension law, social security and employment taxes.
Insurance law is constantly evolving, and changes in financial supervision law are made with great frequency following one after another at a steady rate.
Our litigation teams focus on the most appropriate form of dispute resolution, in and outside of court, from arbitration to mediation. Always looking for the best possible outcome.
Ever-changing government regulations has meant that dealing with the authorities has become an increasingly important aspect of business life.
Ever-changing market conditions require businesses to regularly assess their debt structure
We offer integrated services, in collaboration with both our attorneys-at-law and civil-law notaries.
Today, transfer pricing is one of the main tax issues faced by groups. Whether your business is a high-growth start-up or an established multinational, you need to comply with transfer pricing rules.
International Trade raises significant challenges for many industry sectors.
Based on the Mandatory Disclosure rules, also known as DAC6, taxpayers need to report certain cross-border arrangements (RCBAs) to the Dutch tax authorities.