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