Loyens & Loeff advises clients across the automotive value chain on the tax, regulatory, and transactional consequences of these shifts. Our integrated teams across the Netherlands, Belgium, Luxembourg, and Switzerland combine sector experience with depth in EU law, cross-border structuring, transfer pricing, customs and international trade, M&A, and capital markets – positioning us as a trusted adviser where strategic decisions carry simultaneous tax and legal implications.

How we can help

We support clients across the value chain – OEMs, Tier-1 and Tier-2 suppliers, captive finance providers, mobility platforms, and inbound investors – with the full range of legal and tax services the sector requires.

Transactions and M&A
Cross-border M&A in the automotive supply chain, including Tier-1 and Tier-2 consolidation, OEM carve-outs, joint ventures between European OEMs and Asian battery or e-powertrain partners, distressed acquisitions, and private equity investment in mobility and charging infrastructure.

Capital markets
Equity and debt capital markets work for listed and listing automotive and mobility issuers, including IPOs, secondary offerings, share buybacks, green and sustainability-linked bond issuances, and captive finance funding. Our integrated capital markets, tax, and financial regulatory teams across the Netherlands, Luxembourg, and Switzerland support issuers, underwriters, and sponsors on cross-border transactions.

EU regulatory and trade
Industrial Accelerator Act compliance, state aid, FDI screening, export controls, customs, and preferential origin under new EU FTAs. Our EU law specialists and Brussels-based team works alongside sector specialists in the Benelux and Switzerland on cross-jurisdictional matters.

Tax
Corporate income tax advisory across the value chain, including earnings stripping under ATAD, impairment and deferred tax asset treatment, participation exemption on sector divestments, withholding tax on cross-border flows, and the tax characterisation of contract unwind and settlement payments between OEMs and suppliers.

Transfer pricing
Routine-return benchmarking under margin compression, IP contribution in cross-border JVs, value chain realignment following portfolio rationalisation, and TP controversy with European tax authorities. With our integrated tax & legal expertise and comprehensive transfer pricing knowledge we advise businesses in our main service areas Documentation, Planning & Strategy and Dispute Resolution.

Customs and international trade
CBAM certificate compliance and contractual allocation, preferential origin analysis under EU-Mercosur, EU-India, and EU-Australia, dual-use export controls for defence-adjacent plant conversions, and import VAT and customs valuation issues.

Energy transition and infrastructure
EV charging infrastructure, battery production, grid storage repurposing of battery capacity, real estate and permitting for plant conversions, and renewable energy supply arrangements for manufacturing sites.

Tech, data, and product
Connected mobility and software-defined vehicles, data protection, cybersecurity, IP licensing, commercial contracts, and regulatory compliance for autonomous driving and platform-based mobility.

Workforce and restructuring
Employment, works council, and collective agreement work in plant conversions, reskilling programmes, supplier distress, cross-border insolvency and WHOA restructurings, and captive finance restructurings.

Disputes and controversy
Tax audits and tax litigation, supplier contract disputes, product liability, regulatory investigations, and arbitration in cross-border supply arrangements.

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.
The field of customs and international trade poses significant challenges for many industries.
Based on the Mandatory Disclosure rules, also known as DAC6, taxpayers need to report certain cross-border arrangements (RCBAs) to the Dutch tax authorities.
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Topics

Pillar One & Pillar Two

Pillar One & Pillar Two

Building on years of international efforts to adapt tax rules to an increasingly digitalised economy, the OECD/G20 Inclusive Framework has reshaped the global tax landscape through its two pillar solution.

As part hereof, the OECD/ Inclusive Framework released the Pillar Two Rules at the end of December 2021, resulting in a 15% minimum tax rate for in-scope (multinational) groups in all jurisdictions where they have presence as early as of financial years 2024. These rules are by now introduced in many jurisdictions, imposing a global minimum tax and significantly expanding compliance and reporting obligations for (multinational) groups.

While the OECD has finalised the technical framework for Pillar One, implementation of Amount A remains uncertain due to the absence of global consensus. Amount B, by contrast, is incorporated in the OECD Transfer Pricing Guidelines and can be applied by jurisdictions to determine a return on sales for in-scope distributors.

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.

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.

22-04-2026

On 21 April 2026, Milieudefensie announced a new climate change litigation against Shell. This article reflects on the new proceedings initiated by Milieudefensie.