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An advance tax ruling secures your tax position


From Kiveld you may expect thorough knowledge and experience in:

  • the international tax arena
  • the Netherlands tax laws
  • bilateral and multilateral tax treaties
  • the EU tax regulations
  • the social security regulations
  • tax rulings, e.g. APA’s, ATR’s
  • tax litigation

Kiveld will be happy to assist you in the following tax arenas, amongst others:

Tax structuring

  • Holding structures
  • Foreign branch structures of NL companies
  • Finance and licensing structures
  • Product distribution structures
  • Acquisition structures
  • Internal reorganizations
  • Legal mergers and demergers
  • Assets for shares reorganizations
  • Leasing structures
  • Trust structures
  • Use of administrative trust offices

Tax planning

  • Negotiating and obtaining advance tax rulings
  • Profit remittance optimization
  • Sales and Acquisitions
  • Internal reorganizations
  • Management buy-outs
  • Tax residency movements
  • Debt and equity financing optimization
  • Employee benefit schemes
  • Employee remuneration optimization

Transfer pricing

  • Identifying the intercompany relations
  • Functional and risk analysis
  • Transfer prices analysis
  • Interactions between transfer prices and custom duties
  • Overview recommended adjustments
  • Documentation, such as intercompany agreements

Indirect taxes

  • VAT planning in connection with supplies of goods
  • Registration and set-up of the administration in accordance with VAT regulations
  • Identifying and claiming VAT refunds in foreign countries
  • VAT aspects with respect to corporate transactions and business activities
  • Real estate transactions from VAT and transfer tax perspectives
  • Negotiations with VAT authorities in view of obtaining advance VAT rulings
  • Representation in VAT controversy and litigation
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