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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.

12-05-2022

During the 8th Annual International Tax Developments Seminar, several Loyens & Loeff tax experts as well as officials from the Dutch Tax Authorities updated the participants on the latest internationa

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.

12-05-2022

During the 8th Annual International Tax Developments Seminar, several Loyens & Loeff tax experts as well as officials from the Dutch Tax Authorities updated the participants on the latest internationa

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.

Digital Economy Tax

Politically it is clear that both the EU and other jurisdictions wants to levy more tax from ‘digital companies’. Technically, the current international tax framework does not facilitate this. Fundamental changes seem to be required to achieve the political goals. This could affect both digital and non-digital companies.

20-04-2022

On 4 April 2022 and 14 April 2022, the Task Force on the Digital Economy from the OECD published Draft Model Rules on the Scope and the Extractives Exclusion of Amount A of Pillar One.

How can we help

Help with state aid

State aid has become increasingly important in light of the European Commission intensifying its investigations into illegal aid to private companies from national and local governments. We can assess your state aid risks and help you to reduce and control them, and represent you if you are investigated.

Tak­ing cas­es to court

When going court, we can support you through the process. We are adept at taking cases to the EU courts at every level; we have a strong track record in bringing Dutch, Belgian and Luxembourg-related cases.

Ex­pert opin­ions

We have a highly experienced team of experts that provide expert opinions or other type of legal advice regarding EU tax disputes not only in Belgium, Luxembourg and the Netherlands, but in every other country as well.

When advising your company on state aid matters, we pull together our competition law experts and tax/transfer pricing specialists to best service your requirements.
We offer integrated services, in collaboration with both our attorneys-at-law and civil-law notaries.
Tax authorities are becoming more determined in their approach to tax disputes.