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How we reduced the costs and paperwork for a group of foreign private investors

Note: due to the privacy of our clients, this case study provided by TGS lime tree does not include any names, numbers and other sensitive information of our clients, partners and other parties involved. The client’s problem A group of foreign private investors has invested in residential real estate in the city center of Amsterdam. […]

| 18 January 2019
2
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How we ensured that seafood was allowed to cross the border

Note: due to the privacy of our clients, this case study provided by TGS lime tree does not include any names, numbers and other sensitive information of our clients, partners and other parties involved. The client’s problem In this case, we are discussing a client who imports seafood from Turkey to the Netherlands, in order […]

| 7 January 2019
2
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How we successfully applied for the reverse-charge mechanism on import

Note: due to the privacy of our clients, this case study provided by TGS lime tree does not include any names, numbers and other sensitive information of our clients, partners and other parties involved. The client’s problem In this case, we are discussing a client who imports goods from China and the United States, in […]

| 27 December 2018
2
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Transfer of shares in Chinese subsidiary

One of our clients is a Dutch holding company that wished to transfer a number of its foreign subsidiaries to another group company. These subsidiaries include companies in China, the UK and Korea. Client has been using local accountants in these countries over the past years. It was client’s desire to restructure the shareholdings in […]

| 31 October 2018
2
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Moving a company out of the Netherlands

One of our clients is a Dutch holding company held by two Maltese corporate shareholders. The Maltese shareholders have decided – due to organizational reasons – to move the Dutch holding company to Malta. As the holding company was incorporated under Dutch law, but now registered in Malta, it will be considered as a tax […]

| 21 July 2018
2
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Advantages of a Dutch CV

We are now advising a group of non-Dutch residents that invested in a modest real estate portfolio in Amsterdam. They invested via a limited partnership, a so-called Commanditaire Vennootschap, also known as the CV. The advantages of a CV is that investors (partners) can opt the CV to be treated as fiscally transparent, or as […]

| 29 May 2018
2
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VAT due diligence debt portfolio

One of our clients considers to purchase the shares in a few Dutch companies that hold a considerable debt portfolio. We were requested to perform a due diligence from a VAT perspective on these debt portfolios. One of these companies acquired the debts from a telephone company. Note that if you didn’t pay your telephone […]

| 12 April 2018
2
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Dividend to the US

One of our clients is a US pharmaceutical company with operations in the Netherlands. The Dutch operations are conducted through a Dutch BV company. The shares in the Dutch company are held directly by the US operating company. Fortunately, the BV company has generated profits. If the Dutch BV company distributes a dividend, the dividend […]

| 15 February 2018
2
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Dutch tax aspects of a trust

Our friends from our TGS Global member firm in Ontario (Canada) asked us to assist in a very interesting case. One of their late clients established a family trust many years ago. The trust owned among others shares in several Canadian businesses. One of the beneficiaries of the trust is now a Dutch resident. The trustee of […]

| 21 January 2018
2
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VAT distance sales

One of our clients is a company selling “perfect pieces of furniture” through a web shop. Its customers are private individuals living all over Europe. For VAT purposes these sales can be regarded as “distance sales”. As a main rule the company has to register itself and pay VAT only in the EU country of […]

| 21 December 2017
2
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Repayment of share premium: subject to dividend tax?

We serve another Dutch holding company that was held by an offshore company until recently. The offshore company granted an interest free loan to the Dutch company in 2013. The new bookkeeper of the company erroneously reported the loan as “share premium” in the 2013 financial statements. A few years later the loan was repaid. […]

| 14 November 2017
2
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German exit tax

A Dutch BV-company has been held by different shareholders now residing in both Germany and the Netherlands. Upon request of one of the shareholders a personal holding company will be created. However, before doing so we had to figure out the German personal income tax aspects as well, as the shareholder was a former resident […]

| 31 October 2017
2
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Demerger of a Dutch company

Another client of our firm is engaged in electronic services. It was the intention of client (a German owned BV-company) to separate its Dutch business in separate legal entities. For that reason we advised to make use of the demerger facility in Dutch tax law that makes it possible to transfer certain assets and liabilities […]

| 20 October 2017
2
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Exemption of Dutch real estate transfer tax (2)

Do you remember our case study, whereby we requested for confirmation of an exemption of 6% real estate transfer tax? Well, the Dutch tax authorities honored our request. The Dutch company could sell the real estate to a new group company (exempt of real estate tax). Subsequently, the Dutch company repatriated the proceeds of the […]

| 6 October 2017
2
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Common Reporting Standards form – Deutsche Bank

One of our clients came to us with a Common Reporting Standards form that their Dutch company received from the Deutsche Bank. The Dutch company still had a dormant bank account with Deutsche. Obviously we have been assisting our corporate clients with CRS and FATCA formalities. This was the first time, however, that we filled […]

| 20 September 2017
2
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Earnings stripping rule

Today we finalized a Dutch corporate income tax return for a Dutch real estate company owned by a Luxembourg fund. The real estate company was typically funded with shareholder’s loans. Obviously, the loans had to be interest bearing. In 2019 the Dutch corporate income tax act will be amended as a result of the Anti […]

| 18 September 2017
2
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Transfer of shares French subsidiary

You may remember our client from Hong Kong with its Dutch subsidiary. Client intends to transfer the shares in its French subsidiary to the Dutch company. At present we are analyzing the most tax efficient way to transfer the French shares. This could be done for instance by way of a sale of the shares, […]

| 18 September 2017
2
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Exemption of Dutch real estate transfer tax

One of our clients is about to sell its shares in a Dutch company to a foreign company. The foreign buyer however, is, not interested in taking over the ownership of the factory building owned by the Dutch company. We are assisting client with separating the factory from the Dutch company first prior to the […]

| 11 September 2017
2
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Dividend to Hong Kong

One of our clients is based in Hong Kong. The Hong Kong holding company owns several operations abroad, including in the Netherlands. The client wishes to have certainty about the applicable dividend withholding tax rate on dividends to be paid by the Dutch company to the Hong Kong corporate shareholder. At present we are preparing […]

| 1 September 2017
2
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Dividend to Turkey

Nearly all our clients are foreign owned companies. Hence we are often confronted with questions about dividend withholding tax. Especially when profits are about to be repatriated from the Dutch company to the foreign shareholder. The tax rules can be quite complex. On top of that new rules in relation to the Dutch dividend withholding […]

| 1 September 2017
2