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International Tax

Netherlands

Sound tax advice is absolutely essential where international mergers and takeovers, private equity, international tax planning and transfer pricing are concerned.

By devising and developing the right legal structure, unnecessary tax bills can be avoided in an international merger, takeover or private equity transaction. Extra tax advantages can also be achieved wherever possible. Not only does Dutch taxation need to be taken into account, but taxation in other countries too. CMS has detailed knowledge and wide experience in this area. In addition, our tax specialists carry out due diligence studies for tax purposes into Dutch targets, identifying and listing the tax risks involved. We can also advise you on the tax aspects of setting up investment funds. Our work also includes writing or assessing the tax elements of prospectuses.

When optimizing your international tax position, the aim of our advice is always to minimize the total tax burden of the international group, within workable parameters. Advice on setting up international holding, financing and royalty structures also plays an important role here.

The tax authorities require international companies to have a firm basis supporting the way in which they allocate turnover and costs to subsidiaries in the various countries (transfer pricing system). Together with our partners in the international CMS organisation, we provide advice on transfer pricing and assist you in your negotiations with the tax authorities, both at home and abroad.

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March 2019
Tax­a­tion of the di­git­al eco­nomy
This pub­lic­a­tion aims to identi­fy vari­ous as­pects of the di­git­al eco­nomy and to con­sider wheth­er in­come taxes are the most ef­fect­ive and ef­fi­cient way to tax this eco­nomy. Do we need a re­volu­tion in the tax sys­tem?
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March 2020
CMS Tax Glob­al Bro­chure
At the start of the 2020s, the roles of cor­por­ate tax plan­ning and reg­u­la­tion are un­der in­creas­ing scru­tiny as ques­tions of eth­ics and cor­por­ate cit­izen­ship con­tin­ue to rise up the com­mer­cial and trade policy agenda.Tax be­ha­viour is now a ma­jor fea­ture of cor­por­ate repu­ta­tion, with in­stant com­mu­nic­a­tion put­ting in­tense pres­sure on in­ter­na­tion­al com­pan­ies to pub­lish in­form­a­tion on how they meet their tax ob­lig­a­tions and man­age tax risks. The EU’s man­dat­ory re­port­ing re­quire­ments for cross-bor­der tax ar­range­ments (the DAC6 re­gime) carry heavy sanc­tions for non-com­pli­ance. With DAC6 be­com­ing fully ap­plic­able across the EU on 1 Ju­ly 2020, dis­clos­ure is a key is­sue for in­ter­me­di­ar­ies, tax­pay­ers and na­tion­al tax au­thor­it­ies.Fisc­al trans­par­ency and fair­ness are key con­cepts not just for en­ter­prises and in­di­vidu­als, but for the gov­ern­ments and fin­an­cial in­sti­tu­tions who com­pete to pro­mote and at­tract in­ter­na­tion­al trade and in­vest­ment. The G20/ OECD pro­ject to tackle base erosion and profit shift­ing (BEPS) has brought to­geth­er over 135 coun­tries in a col­lab­or­at­ive ef­fort to com­bat tax avoid­ance.Di­git­al­isa­tion is a key fo­cus of the BEPS pro­ject. As the glob­al di­git­al eco­nomy con­tin­ues to pro­duce new products, ser­vices and com­mer­cial prac­tices in every sec­tor, it raises a host of new ques­tions for in­ter­na­tion­al tax policies and struc­tures. On­line mar­kets and their tax im­plic­a­tions for do­mest­ic and cross-bor­der trans­ac­tions are hav­ing game-chan­ging ef­fects on how and where busi­ness is done.Many tax au­thor­it­ies are ramp­ing up their en­force­ment ac­tions, armed with stiffer pen­al­ties and a more tar­geted ap­proach to in­vest­ig­a­tions. The net res­ult? Tax­pay­ers of dif­fer­ent kinds – mul­tina­tion­als, fin­an­cial in­sti­tu­tions, funds, in­vestors and high net worth in­di­vidu­als – are fa­cing in­creased tax risks and pres­sures. The right ad­vice can make all the dif­fer­ence. Ex­perts can help you shape your strategy, man­age the risks and make the most of the op­por­tun­it­ies in the tax land­scape of the 2020s.

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April 2020
CMS Guide to Real Es­tate Trans­ac­tion Costs and Taxes in Europe
June 2019
Do tech com­pan­ies hold the solu­tion to tax­ing the di­git­al eco­nomy?
06 June 2018
Tax avoid­ance in a glob­al­ised world
This Guide il­lus­trates the on­go­ing de­vel­op­ment of anti-avoid­ance tools on every con­tin­ent. Africa, Europe, Lat­in Amer­ica and Asia are equally con­cerned. In­spired by..
22 April 2018
CMS Guide to tax re­gimes in Cent­ral and East­ern Europe
04/04/2017
Brexit: Groups of Com­pan­ies and Tax Treat­ies
16/10/2014
Trans­fer Pri­cing - A stra­tegic ap­proach for glob­al busi­ness per­form­ance
15/07/2014
China tax reg­u­la­tion up­date - June 2014
15/09/2011
CMS pub­lishes Guide to Cross-Bor­der Mer­ger and on­line trans­ac­tion plan­ner
15/09/2011
CMS Guide to Cross-Bor­der Mer­ger 2011
11/07/2011
CMS ad­vises Uni­pa­pel on bind­ing of­fer for cross-bor­der ac­quis­i­tion
28/12/2010
China Im­poses Ad­di­tion­al Tax on For­eign En­ter­prise, In­ves­ted En­ter­prises...
08/12/2009
Lim­it­a­tions in de­duc­tions for ac­quis­i­tion hold­ings and for­eign branches