;
Branding icon

ATAD2

The anti-hybrid mismatch rules of the EU Anti-Tax Avoidance Directive (ATAD2) aim to prevent situations of a double deduction and a deduction without a corresponding inclusion of the income at the level of the recipient resulting from a hybrid mismatch. All EU Member States have implemented ATAD2 in their domestic laws as from 1 January 2019 (for Belgium) or as from 1 January 2020 and 1 January 2022 (for a.o. the Netherlands and Luxembourg).

05-03-2021

Following the second EU anti-tax avoidance directive, the further implementation of the reverse hybrid rule entering into force as of 2022.

Implementing Pillar One & Pillar Two

To adapt 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. Tax directors and their teams can already model the impact and assess opportunities for manageable restructurings to mitigate the increased complexity.

22-09-2022

The new edition of the EU Tax Alert is available. With this publication we would like to keep you informed about the latest developments on EU 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 European Commission recently issued a new proposal (ATAD 3). It is highly recommended that taxpayers assess the possible impact of the proposal and consider opportunities for strengthening their local footprint and/or restructuring.

13-07-2022

In a Decree of 8 July 2022 the State Secretary of Finance withdraws the approval for the application of the exemption method for board member and supervisory board member fees.

How we can help

Structuring and taxation are our strengths. These enable us to anticipate tax pitfalls and integrate tax aspects at all stages of a transaction initiated by a private equity or real estate fund. This includes the possible legal and tax implications (and future exit proceeds) of such a transaction, for both the fund and its investors. We can also assist in the post-closing legal and tax compliance.

With an integrated approach that sets us apart in the market, we offer our clients a unique combination of legal, tax and regulatory advice.
Effectively managing your indirect tax position and remaining competitive while avoiding risks.
The Loyens & Loeff Project Development & Construction team combines real estate experts from across our three disciplines – lawyers, civil law notaries and tax advisers.
Whether you are buying, selling, partnering or investing in a company, the success of mergers and acquisitions (M&A) as a growth strategy relies on getting expert answers to your questions.
How do you structure your investment vehicle and your acquisition when legislation is ever-changing, nationally and internationally?
Tax compliance is about more than submitting an accurate tax return on time.
Loyens & Loeff helps simplify the process by offering you a one-stop shop for all your M&A needs, including those which relate to tax.

What others say

Quote icon
“We laud Loyens & Loeff for its commercial acumen and its very pragmatic & business-friendly approach."
Chambers Europe (2021)
Quote icon
“The team makes a real effort to understand what we need on a daily basis."
Chambers Europe (2021)
Quote icon
“Lawyers are very up to date in their understanding of the Dutch financial services regulator. They have set up or advised many Dutch funds, so have very good overview of what are acceptable conditions for the national authorities.''
Chambers Europe (2020)
Quote icon
"Excellent service and availability. Speed is key in our field and they deliver.”
Legal 500 (2020)
Quote icon
"Loyens & Loeff’s investment management practice offers truly integrated services. They smoothly combine tax, legal and regulatory aspects in their approach."
Legal 500 (2021)
Quote icon
"They are very experienced and reliable, react fast and are always to-the-point."
Legal 500 (2021)
Quote icon
"We highly appreciate their experience and great network among financial market and tax authorities."
Legal 500 (2021)
Quote icon
"They provide excellent materials for our local tax and legal & regulatory committees and by contributing to yearly recurring training programs for both junior and senior investment managers."
Legal 500 (2021)
Quote icon
"All top tier advisors with outstanding technical skills, which they combine with hands-on advice."
Legal 500 (2021)
Quote icon
"The Loyens team works collaboratively, efficiently, and quite creatively."
Legal 500 (2021)
Quote icon
“On top of the current developments, good network within government agencies. Pragmatic and focused.”
Legal 500 (2021)
Quote icon
“The team offers a full-service approach, combining the different disciplines. Seems to be most knowledgeable of market practices.”
Legal 500 (2021)
Quote icon
"Loyens & Loeff has a deep knowledge of applicable law, a commercial focus and a wide view of the market."
Legal 500 (2021)
Quote icon
"The team picks up a tremendous flow of work directly from clients, as well as from leading international law firms, across a range of primarily alternative investment funds and related capital raising, structuring and regulatory issues."
Legal 500 (2021)
Quote icon
"The lawyers are friendly and responsive business-enablers."
Legal 500 (2021)
Quote icon
“Together with Loyens, we have essentially invented a unique Venture Fund set-up, which was necessary due to our particular mandate, style, investors and the diverse geographies that we invest in. This has meant that Loyens has had to pull in partners from diverse practice groups to work with us as a flexible and fast-moving team. All of this is accomplished in a cohesive and collegiate fashion, that is distinct and much appreciated.”
Legal 500 (2021)
Quote icon
"True understanding of clients' needs, responsiveness and large team."
Chambers & Partners Europe (2022)
Return to previous slide
Go to next slide