US multinational companies, investment companies and individuals often use the Netherlands as a gateway to Europe and the rest of the world. VanOlde is in an excellent position to offer tailored advice to US clients on the Dutch tax aspects of their investments due to the broad experience of vanOlde’s partners with cross-border Dutch and US tax aspects. Partners of vanOlde have previously been based in New York, they travel to the US on a regular basis and they are members of the American Chamber of Commerce in the Netherlands. Our advice covers the following areas:
1. Dutch and international tax advice
We advise our clients on the following topics in relation to existing structures and in respect of corporate restructurings:
- Holding company aspects, such as the applicability of the participation exemption, CFC rules and withholding taxes
- Financing transactions, including for instance cash pooling
- Transfer pricing planning and documentation
- IP structuring, DEMPE functions, onshoring of IP
- Interest deductibility limitation rules
- Anti-hybrid rules (ATAD2)
- US-Netherlands tax treaty, LOB
- International aspects such as the Multilateral Instrument, Pillar 1 and Pillar 2, EU law, and state aid
2. M&A transactions
VanOlde advises (multinational) corporations, (international) investors, investment funds and anyone else investing in Dutch assets on all tax aspects of M&A transactions. We offer buy-side and sell-side assistance, advise on acquisition and sale structuring and management participation plans and we assist with post transaction integration plans.
3. Tax returns / compliance
We prepare corporate income tax, VAT, withholding tax and real estate tax returns. When necessary, we assist with answering questions of the tax authorities about tax returns that were filed and we assist with tax audits that are conducted by the tax authorities.
4. Tax rulings
We regularly obtain tax rulings on the Dutch tax aspects of structures or specific transactions.