Restructuring a group structure is an irreversible act if the tax consequences have not been mapped in advance.

International restructurings have tax consequences that can be significant and, in some cases, immediate and unavoidable if not properly structured. We advise on the tax aspects of reorganising cross-border corporate structures: mergers, demergers, the contribution of businesses or assets, share exchanges, and the migration of entities or functions between jurisdictions. We work within the framework of Dutch domestic law (including the rollover relief provisions in the Vpb and the dividend withholding tax act), relevant EU Directives (the Merger Directive), and the treaty network. The tax analysis of a restructuring must be completed before the legal steps are taken, not after.