Reliable Solutions for International Tax Planning
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Modern tax regulations demand precision and flexibility. We develop lawful and effective strategies for businesses and personal finances in the Netherlands and abroad, ensuring compliance, protection, and readiness for change.
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Call us at:
+31616123960
What We Offer
- International Tax StructuringComparison of jurisdictions, corporate forms, tax rates, and regimes.
Modeling intra-group assets, functions, and risks.
Calculating tax efficiency across various scenarios. - Tax Restructuring and M&A SupportStructuring transactions to address tax risks.
Conducting tax due diligence.
Preparing and delivering tax opinions. - Transfer Pricing and ComplianceSelecting appropriate transfer pricing methods.
Defining arm’s-length price ranges for intra-group transactions.
Preparing documentation to meet tax authority requirements. - Negotiations with Tax AuthoritiesTax exemptions (Advance Tax Rulings, ATR).
Application of tax benefits (Advance Tax Rulings, ATR).
Pricing agreements for intra-group transactions (Advance Pricing Agreements, APA). - Tax Planning and Compliance for Individuals
Personal income tax consultations and filings.
International tax planning:
- Relocation and remote work strategies.
- Optimizing business income.
- Structuring employee incentive plans.
- Managing foreign income.
Examples of Our Projects
- International Structuring for Global Business
- Compared tax regimes and modeled a holding structure based on functions, risks, and assets, reducing the tax burden by 20%.
- Conducted comparative analysis and recommended fiscal unity for a client’s parent and subsidiary companies in the Netherlands.
- Designed an employee incentive plan for remote workers via a Holding-B.V. and STAK foundation, assessing tax consequences for RSA, RSU, phantom shares, and stock options.
- Transfer PricingSecured an APA with Dutch tax authorities for Company X, acting as a low-risk distributor, to base compensation on a median operating cost margin with a minimum of 1–5% of turnover for 2024–2028.
- M&A Tax SupportConducted tax due diligence for a client acquiring an e-commerce company in the Netherlands and structured the transaction to minimize tax risks.
- Tax Authority Requests (ATR)
- Secured a ruling confirming that a client’s real estate activities did not exceed the passive management threshold for Box 1 exemptions.
- Negotiated a dividend tax exemption for a foreign parent company and confirmed no corporate income tax liability in the Netherlands.
- Obtained a corporate tax exemption for converting debt into equity in a B.V.
- Achieved interest deductibility for loans taken by a B.V. and confirmed non-application of Article 10a of the 1969 Corporate Income Tax Act.
- International Tax Planning for Private Businesses
- Advised a client to establish a cooperative in the Netherlands (Coop) and a holding company in the UAE to align with future relocation goals.
- Provided guidance (with case law references) on balancing dividends and salaries from a foreign entity.
- Prepared a checklist of actions and documents to mitigate tax risks related to director functions being performed in the Netherlands for a foreign company.
- Compared the corporate, tax, and administrative implications of acquiring Dutch real estate through a local (B.V.) or foreign holding company.
Why Choose Us
- Tailored Solutions:Each strategy is customized to meet the client’s unique needs.
- Comprehensive Expertise:We provide both strategic advice and full support throughout implementation.
- Preparation for Change:Our recommendations anticipate future legislative developments.
- Advocating for Your Interests:We align your position with tax authorities, minimizing dispute risks.
- Reliability:Our professional liability is insured for up to € 2 million.
PLAN YOUR TAXES WITH CONFIDENCE!
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Did You Know?
When relocating from the Netherlands, company owners holding 5% or more shares are taxed in Box 2 on the increase in share value during their time in the country. However, owners of foreign companies can avoid this tax if they have lived in the Netherlands for less than 8 consecutive years and no more than 10 years in the past 25 years (passantenregeling).
When relocating from the Netherlands, company owners holding 5% or more shares are taxed in Box 2 on the increase in share value during their time in the country. However, owners of foreign companies can avoid this tax if they have lived in the Netherlands for less than 8 consecutive years and no more than 10 years in the past 25 years (passantenregeling).
A discovery call or a tax consultation?
We will contact you as soon as possible
Contacts
For the fastest reply find us in Telegram: @VladBurilov
Vlad Burilov
vb@saltpartners.nl
+31 61 61 2 39 60
Slava Konizhevskiy
vk@saltpartners.nl
+31 611 75 12 65
Visit our office: 5211 TV Stationsweg 19, 's-Hertogenbosch
vb@saltpartners.nl
+31 61 61 2 39 60
Slava Konizhevskiy
vk@saltpartners.nl
+31 611 75 12 65
Visit our office: 5211 TV Stationsweg 19, 's-Hertogenbosch