International structures do not fail at inception. They fail when the underlying tax analysis has not kept pace with changes in law, structure, or business.

International Tax

We advise businesses and individuals on the international dimensions of their Dutch and cross-border tax position. Our work covers tax treaty interpretation and entitlement, the prevention of double taxation, the analysis of permanent establishment risk, and the structuring of inbound and outbound investments. We advise on BEPS-related legislation — including the Dutch implementation of Pillar Two (GloBE), ATAD I and II, CFC rules, and hybrid mismatch provisions — as well as on substance requirements that are increasingly subject to scrutiny by the Dutch and foreign tax authorities.

What we do?

  • Tax treaty analysis: entitlement, tie-breaker provisions, and woonplaatsgeschillen
  • Permanent establishment: risk assessment, prevention, and attribution of profits
  • Inbound and outbound investment structuring
  • Pillar Two / GloBE: applicability analysis, top-up tax calculations, and filing obligations for Dutch entities
  • ATAD I and II: interest deduction limitations, CFC rules, hybrid mismatches, and exit taxation
  • Controlled foreign company (CFC) analysis under Dutch tax law
  • Substance requirements: documentation and assessment
  • Country-by-country reporting (CbCR) and BEPS Action Plan compliance

Who is it for?

  • Multinational groups with Dutch entities, Dutch holding companies, or a Dutch headquarters
  • International entrepreneurs expanding into or out of the Netherlands
  • Family offices with assets held through multi-jurisdictional structures
  • Foreign companies establishing operations or a tax presence in the Netherlands
  • Individuals with complex treaty residency positions
CONTACT US

Let's get in touch

At Taxboutiq, we are ready to provide you with the expert advice and personalized support you need to achieve your financial goals. Whether you have a question about our services, need assistance with tax planning, or want to schedule a consultation, our team is here to help. Contact us today!