Examples of international corporate questions include the case of a Dutch company which wanted to extend its operations in another country. The company wanted to know whether it would be better to start these new operations through a representative office, a permanent establishment or by incorporating a new limited company. Innovative Tax frequently acts as tax counsel for foreign companies with international holding, finance and royalty structures in or via the Netherlands. Key issues in these structures are the optimization of the international tax structure, correct transfer pricing including documentation requirements and the minimization of withholding taxes.
Often foreign companies, often from the United States, choose the Netherlands as the base for their European holding company. From here, they expand their European operations by gradually incorporating more European operating businesses in different countries with interesting market opportunities. One of the reasons is the fact there is no Dutch dividend withholding tax due on profit distributions from the Dutch European holding company to its United States shareholder if there is compliance with the conditions mentioned in the US / Dutch tax treaty to avoid double taxation.
In this respect it is worth mentioning that the Netherlands has an excellent network of tax treaties (about 90 tax treaties) with other countries to avoid double taxation. Furthermore, as a member of the European Union (EU), tax residents of the Netherlands are entitled to the benefits of the EU Parent/Subsidiary directive, EU Merger directive and the EU Interest & Royalty directive. When there is compliance with the conditions, there will be no withholding tax in the (EU) source state. The beneficial owner can enjoy his/her profit distribution without any foreign withholding tax.
When working on international tax matters alongside our network of trustworthy independent local tax advisors, we do our utmost to meet our clients’ specific needs and expectations.
Innovative Tax has broad experience with international tax advice services. Please feel free to discuss the (im)possibilities of your case or needs with us. We will be happy to provide you with an estimate of the expected costs. After your approval, we will start our activities.
Innovative Tax specializes in international tax planning and advice. In previous years, Innovative Tax has built on its experience with solving complex international tax matters. For example, we were asked by a Dutch tax resident engaged in professional diving activities whether it would be a good idea to structure these global activities through a Delaware Limited company. Another example concerned a Dutch tax resident employed by a Jamaican/US cruise ship company and who was a professional cook on a cruise ship which sailed under a Maltese flag. We were asked about the tax and social security consequences.
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- Tax counseling relating to mergers and acquisitions
- Tax counseling relating to the R&D innovation box
- Tax counseling relating to the emigration of you or your company
- Tax counseling relating to expatriate workers
- Tax counseling relating to tax law proceedings at the (high) Court
- Tax counseling relating to international tax matters
- Managing your private and corporate tax compliance
- Providing (in-house) training on international tax matters
- Optimizing the tax position of the company and that of the director-shareholder(s) in private