As of April 2011 flight personnel living in The Netherlands, and who work for an airline company located in Great Britain, will face some changes in their (future) taxation. This is because the treaty of avoidance double taxation between The Netherlands and Great Britain has been revised, amongst others with respect to the taxation of flight personnel. To summarize, as of April 2011 flight personnel will temporarily have a choice as to in which country they are effectively taxed.… Read More
Transfer Pricing – Highlights in the Netherlands
The term ‘transfer pricing’ stands for setting prices for internal transactions between a related multinational group of entities. Transfer pricing may well lead to a tax benefit when part of the group is located in tax friendly countries. … Read More
Summary of the requirements 30%-ruling
On regular basis we advise expats and/or their employers on the 30%-ruling, part of this advisory is preparing the actual request for the ruling. As the interest of being granted the ruling can be very high, it is worthwhile to invest sufficient time to assess the exact situation of the employee compared to the applicable legal requirements. … Read More
Stamrecht BV / Standing right company
Please note as of the year 2014 it will most likely not be possible any more to use the stamrecht facilities, please see our recent article.
In case of a severance payment a so called stamrecht or standing right limited liability company (BV) can be incorporated by the employee; the recipient of this severance payment. To this stamrecht BV the severance payment can be paid by the former employer without withholding any wage tax/premium. Depending on the facts it may be differ, but starting from a severance payment in excess of appr. EUR 75,000 a stamrecht BV may well be interesting. In case the employee has the benefit of the 30%-ruling, the BV can be used to retain this ruling and its benefits. … Read More
Tax, premium social security and employer healthcare insurance contribution benefit in the year of migration
In most cases a tax and premium benefit can be achieved in the year of migration, either moving to or moving out of the Netherlands. As to the premiums this benefit follows from the fact that premium can be calculated on a time related basis. … Read More
Non businesslike loan (onzakelijke lening) and thin capitalisation rules
The Netherlands is a country which is often integrated in international tax structures, mostly due to its advantageous tax regime, overall beneficial tax treaties and its well organised / reliable infrastructure. Often these tax structures are set up for holding and/or finance activities between related parties. During the years a lot of corporate income tax legislation, policy and case law has been published with regard to the deductibility of interest for Dutch tax purposes. In some cases certain ‘loans’, which were labelled as such by the tax payer, have been succesfully requalified by the Dutch tax authorities as being capital. … Read More
