Corporate Tax

Corporate tax has become increasingly complex in recent years due to the continuous adjustments and the impact of international laws and regulations, including the many anti-abuse measures, substance requirements, interest deduction restrictions and exception provisions, but also documentation obligations, the implementation of ATAD 2 & 3, Pillar 1 & 2 , the CFC legislation and the reporting obligation for cross-border tax arrangements (DAC6).

STP guides its clients through a team that has rich practical experience combined with in-depth knowledge and expertise in all aspects of corporate taxation and the tax regulations that apply (national tax law, European rules and bilateral tax treaties).

A broad and specialized team assists your company with regard to issues such as the application of the participation exemption, the (re)financing of your company, mapping and optimizing the tax position and structure of your company, compliance and implementation activities, but also preparing and submitting requests, notices of objection and appeal and consultation with the tax authorities.

The STP team has a solid track record in all areas of corporate tax, including services related to:

Financing and Interest Deduction Limits
Innovation facilities (such as the innovation box)
Investment facilities
Participation exemption
Tax treaties
Loss Settlement
Permanent establishments
Set up and reorganize (international) group and holding structures
Guidance on mergers, divisions and fiscal unity issues
Mergers and acquisitions
Private Equity and fund structures
Advanced Tax Rulings (ATP) or Advanced Pricing Agreements (APA)
Negotiations with the Dutch tax authorities, dispute resolution and tax audits
International structuring (participation exemption, dividend tax and foreign tax liability)
Tax opinions and second opinions

International Tax

The tax rules are very complex. In international situations, the complexity increases even more. These aspects involve many different areas such as convergence of different legal systems, rules on permanent establishment, the structuring of cross-border financing, the application of tax treaties and the Multilateral Instrument (MLI).

STP Tax deals with international tax issues on a daily basis and has gained extensive experience in this area. Our specialists constantly keep their knowledge up-to-date. STP Tax also has an extensive international network of legal and tax service providers. We are happy to use our expertise and network to guide your company in meeting Dutch and international tax obligations and setting up an optimal structure.

STP Tax can assist your company in various cross-border situations. Among other things, we can help with:

Advice regarding the dividend tax position, including application of the withholding exemption, the technical substantial interest and the Principal Purpose Test (PPT) from the MLI
Managing risks in the international structure, including DAC6, ATAD and shaping a tax control framework (TCF)
Preliminary consultation with the Dutch tax authorities about certainty of the tax consequences in advance (APA/ATR practice)
International transfer pricing and corporate restructurings
Advising on financing and licensing activities, including deduction restrictions such as the earnings stripping measure, anti-profit drainage and ATAD 2
Tax matters relating to real estate in cross-border situations, permanent establishments and profit allocation
Cross-border acquisitions, including (vendor) tax due diligence, guidance with transaction documentation and post-closing structuring
Setting up internationally operating investment funds
Cross-border employment, such as aspects related to the 30% facility and employee participations (ESOP)
Advice on the international VAT position
Disputes in the field of international information exchange
Tax residence discussions of companies and individuals