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How do you structure your investment vehicle and acquisition with ever-changing national and international legislation? How do you uphold an unblemished reputation and simultaneously maintain an efficient tax structure? How do you monitor day-to-day compliance in an increasingly regulated environment and safeguard your investment return? These questions reflect the importance and relevance of our renowned real estate taxation advice.
Structuring and taxation are our strength. They enable us to anticipate tax pitfalls and integrate tax aspects at all stages of a project, keeping in mind that decisions made, even in the early stages of an investment, can have a significant impact on the profitability. We also advise on all taxation aspects relating to public-private partnerships.
Sustainability is becoming an increasingly important factor in the decisions of investors, companies, consumers, shareholders and policy and law makers. The broadly supported awareness of Environmental, Social and Governance (ESG) objectives is reflected in many international voluntary standards as well as in an increasing number of European regulations.
The publication ‘Project development & construction in the Netherlands’ offers a clear overview of the key legal and tax aspects of project development and construction.
Our firm had the privilege of advising APG, acting on behalf of Pensioenfonds ABP, on their strategic investment alongside existing co-investors in SkyNRG
The anti-hybrid mismatch rules of the EU Anti-Tax Avoidance Directive (ATAD 2) 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).
It is noted that EU Member states can introduce rules that go beyond the minimum standards of the ATAD2 directive. An example of this is the introduction of the ATAD2 documentation requirement in the Netherlands. Following the Dutch ATAD2 documentation requirement, all Dutch taxpayers should have documentation available in their administration that shows the (non-)applicability of the ATAD2 rules.
This first circular from the Luxembourg tax authorities provides clarifications on tax status of a hybrid entity, its taxation rules and obligations in Luxembourg.
Luxembourg is the main jurisdiction in Europe for launching credit funds with a European strategy.
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.
This Snippet describes the treatment of reverse hybrid entities under Pillar Two.
On 22 March, the Luxembourg Accounting Board published Q&A 25/035, providing further accounting guidance on the impact of the Pillar 2 rules. Read more!
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.
On 25 April 2025, the Dutch Supreme Court (Supreme Court) issued two landmark decisions on certain anti-abuse rules relevant for non-Dutch entities holding shares in Dutch taxpayers.
The topic of this Snippet is the proposed EU Transfer Pricing (TP) Directive (the TPD). If adopted, the TPD may impact U.S. multinationals with operations in Europe.
