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Johann Muller - The Netherlands in International Tax Planning. Second Revised Edition IBFD

This book is first and foremost aimed at foreign international tax practitioners with corporations as their clients, If you are an adviser to individuals this book will have useful information on how your client's companies in the Netherlands will generally be treated, but it will not tell you how foreign individuals are taxed in the Netherlands and what estate planning techniques could be used.

This book aims to go further than many loose-leaf editions which give a global overview of corporate taxation in the Netherlands: it makes little sense to write something again that is out there already. First. I have tried to cover what I believe is the relevant material that a foreign international tax practitioner comes across as opposed to a national professional. In my mind international professionals are not that interested in knowing about the tax issues that typically play at an operating company level: investment incentives and divestment clawbacks, or labour cost incentives. Instead, they want to know about cross-border flows of funds and services, acquisitions, disposals, mergers, the prevention of double taxation and to some

extent tax consolidation (but again, not the nitty gritty at opco level).

I have also tried to illustrate what is being said by providing as many examples as possible. Often an example does little more than repeat what has already been said. However, if it makes the difference between understanding and not understanding what has been said, or if it create a new perspective on the understanding of what has been said, it is worth it.

Finally, in dealing with the various topics, I have tried to stay as close a possible to the law, case law and the various publications of the tax authorities. Each topic begins with a description of what the law says. It is then amplified through the use of examples, quotes from the legislative history and case law. The guidance and comments given by the tax. authorities is discussed separately since it generally does not represent the law as such, but only the authorities' interpretation of the law.

This book covers developments in Dutch tax law up to 2 May 2007.

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