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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.

28-11-2024

As 2024 nears its end, it is time for our annual tax update. This update focuses on the tax trends and developments we foresee for 2025 and includes tips and takeaways.

ATAD2

ATAD2

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.

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.

28-11-2024

As 2024 nears its end, it is time for our annual tax update. This update focuses on the tax trends and developments we foresee for 2025 and includes tips and takeaways.

Environmental, Social & Governance (ESG)

Environmental, Social & Governance (ESG)

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.

28-11-2024

As 2024 nears its end, it is time for our annual tax update. This update focuses on the tax trends and developments we foresee for 2025 and includes tips and takeaways.

Digital Economy Tax

Digital Economy Tax

Addressing the tax challenges of the digitalizing economy has become a priority within the OECD as well as within the EU. Both the OECD and the EU have launched proposals and developments follow each other rapidly.

06-11-2024

Late 2022 the European Commission published a legislative proposal regarding VAT in the digital age (the ViDA proposal). The European Council has finally reached political agreement on an amended version of the ViDA proposal.

How we can help

Our in-depth knowledge, expertise and practical experience cover all of the various tax and legal areas relevant for your company. We can help with the whole range of tax and legal issues, from advice on mergers and acquisitions to transfer pricing, EU law and dealing with the tax authorities. Our highly experienced team also takes a broad view and looks beyond the specifics of your particular request to identify the best way of helping your business.

Our Tax practice is by far one of the largest among European law firms. Although the practice is comparable to that of any of the Big Four accounting firms in terms of numbers, you will find that our approach is very different. We focus on building strong relationships with our clients, providing personal service and acting as your trusted adviser.

We stand out from other law firms with our flat organisational structure, entrepreneurial mindset and pragmatic approach. We work in small teams and our partners provide plenty of hands on support. We also tailor our services to your precise needs, whether that’s a straightforward e-mail response or more considered advice.

Organisations operating in Europe must keep abreast of EU tax law developments. Our team monitors developments and keeps you informed.
Do you own a family business? Are you an entrepreneur? Or maybe a high net worth individual?
Effectively managing your indirect tax position and remaining competitive while avoiding risks.
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.
Tax authorities are becoming more determined in their approach to tax disputes.
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.
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.
The field of customs and international trade poses significant challenges for many industries.
Stay up to date on recent developments
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“Strength in the international tax area, multi-jurisdictional coverage in the Benelux region, close connections to tax agencies, and presence in New York city.”
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“Ability to translate technical tax rules into actionable business decisions, ability to collaborate across different firms, capacity to creatively brainstorm solutions and familiarity with working with multinational, publicly traded corporate clients.”
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Chambers & Partners Europe (2023)
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"They are fantastic at handling complex issues and the team has strong depth and breadth of expertise."
Chambers & Partners Europe (2023)
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"Loyens is very strong in Dutch and Luxembourg tax. We have consulted them on a number of proposed restructurings involving both countries, and their advice is timely, well supported, and client friendly. We have no issues introducing them to our clients in this regard."
Legal 500 (2022)
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"I choose Loyens for particularly complex tax work. The reasons I choose them include: deep knowledge of Dutch tax laws, anticipation, very high standards, truly understanding of clients needs, responsiveness, large teams, involved partners."
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"The firm has one of the best tax practices in the Netherlands. They are very professional, responsive and friendly to clients."
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Chambers & Partners Europe (2022)
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