As Dutch tax advisors, we issue Dutch tax opinions. Because our specialty is Dutch corporate income tax and Dutch dividend withholding tax our Dutch tax opinions typically focus on this area of Dutch tax expertise.
Dutch corporate income tax opinion
Although the Dutch corporate income tax legislation application might not be straight forward in many cases, our Dutch corporate income tax opinions typically cover the application of the Dutch base erosion rules and the application of the Dutch participation exemption. In international restructurings, these topics seem to be the most important ones.
Dutch dividend withholding tax opinions
The Dutch dividend withholding tax rate is 15%. However, under the application of tax treaties, this rate might be mitigated. Anti-abuse rules such as dividend stripping and beneficial ownership requirements apply. In addition, it may be possible to do repurchase of shares, or a repay share premium. The Dutch dividend withholding tax opinions we issue typically cover the before mentioned and provide a level of comfort as to the desired outcome.
Dutch tax provisions
To determine a tax provision it is of importance to determine the applicable accounting principles and be able to quantify the incurred risks and/or exposure. We can quantify these tax risks and tax exposures for Dutch GAAP, US GAAP (FIN48 analysis), and IFRS.
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