This book provides international tax professionals with a practical guide on dealing with the Dutch taxation of business investments into the Netherlands, via the Netherlands (conduit structures), or from the Netherlands. The book focuses on corporate income tax, dividend tax and capital duty, as well as other issues typical of an international environment (participation exemption, the current state of the ruling practice, financing). The contents include: introduction to Dutch domestic law, including both corporate and personal income tax, dividend withholding tax, VAT, real estate transfer tax; an in-depth analysis of the Dutch corporate income tax system including financing a taxpayer, tax consolidation, holding companies and participation exemption, corporate reorganizations, financing companies, transfer pricing, loss compensation, inbound investments and anti-abuse legislation; participation exemption and Dutch interest limitation rules; royalty and interest income box, an overview of Dutch international law examining treaties, the tax agreement for the Kingdom of the Netherlands, the unilateral decree for the prevention of double taxation and EU law; a description of Dutch dividend tax including EU entities and dividend tax credit; an overview of the exchange of information including national law, the ruling practice, treaties and EU law; a description of the personal income tax, including 30% cost allowance and employee stock option plans.

This study considers how tax authorities attempt to strike down international tax avoidance structures, in particular those involving the use of conduit and base companies set up by third-country residents for purposes of "treaty shopping" and "EC-Directive shopping". The book focuses on the interaction between provisions and judicially developed doctrines of domestic tax law preventing international tax avoidance on the one hand, and norms of international law, in particular tax treaties and rules of Community law, on the other. It also considers treaty-based anti-avoidance measures such as the "beneficial ownership" requirement and "limitation on benefits" provisions. This part of the study compares and analyses the case law of Australia, Austria, Belgium, Canada, the Czech Republic, Finland, France, Germany, India, the Netherlands, Switzerland, the United Kingdom, and the United States.

The book summarizes the main features of the Netherlands tax system. It provides foreign investors and business people with basic information on the tax implications of their business plans in the Netherlands. The various chapters deal with the General Tax Act, individual income tax, corporate income tax, wage tax, the social security system, dividend withholding tax, VAT, estate tax, gift tax, transfer tax, insurance tax, international and European tax law.

The taxation of international economic activities presents two essential considerations: revenues must be shared equitably by the nations involved, and those nations must be able to enforce their domestic tax laws. Starting from these requirements of reciprocity and enforcement, the author explains in this book the practical issues affecting international taxation of business income and capital gains. Unlike many books on this complex subject, his approach does not examine the tax perspective of any one country, but proceeds from an identification and analysis of the basic principles of the subject. This entails an understanding of factors, such as: domestic tax laws, rules and practices and how they conflict on cross-border transactions; bilateral tax treaties and their role in resolving international tax conflicts; the use of offshore financial centres in international tax structures and how to choose them; anti-avoidance measures imposed by national taxation authorities; and international tax guidelines and interpretations of bodies such as the Organisation for Economic Cooperation and Development (OECD) and the International Fiscal Association (IFA). Basic International Taxation describes each and all of these elements, weaving them into practical planning guidance providing a fundamental understanding of this subject in a single, easy-to-follow book. It explains those principles of international tax planning that take the costs and risks of international taxation fully into account and thereby optimize the after-tax returns on cross-border transactions. Several important current issues, including the taxation of electronic commerce, are also addressed.

The authors of International Tax Planning are tax specialists representing both high-tax and low-tax jurisdictions. They address tax issues that impact business enterprises as well as individuals, presenting a sampling of issues, each addressed by a commentator whose practice deals directly with such matters on a regular basis. Countries covered are: Austria France Germany Gibraltar Italy, Liechtenstein Spain Switzerland the Netherlands Netherlands Antilles U.S.A The reader will find a wealth of useful information, not only on the complexity of international taxation, but also its potential for the resolution of conflicts and the mitigation of unfair tax burdens through amortization and international cooperation.

This work on international tax aims to strip away the mystique that can surround the subject. International tax is now recognised as an important discipline in its own right. The book sets out to synthesise its most important elements.

The book deals with tax planning with holding companies located in Europe, Asia of the Caribbean. It analyses the problem of repatriating U.S. profits from Europe, going far beyond the routing of income via different companies. Instead, the approach includes an analysis of the interdependencies between international tax competition, holding company regimes, and tax planning concepts in order to establish a basis for tax planning measures regardless of the fast changing legal environment for holding companies in the different countries.

This unique book summarizes the main features of The Netherlands tax system. Although the author has tried to give a general overview, the main purpose of the book is to provide foreign investors and business people with basic information on the tax implications of their business plans in the Netherlands. The book deals with the most important aspects of income and corporate income tax. Special attention is paid to the participation exemption applicable under this latter tax. The author also looks at two other taxes almost every investor will be confronted with, such as: taxation upon death property transfer tax the taxation of non-residents The Netherlands tax treaties Taxation in The Netherlands is an indispensable reference tool for company executives, foreign tax consultants, accountants, legal advisers, and students of tax law.

The author highlights the principle planning techniques which are available to multinational enterprises such as international holding and finance companies, royalty routeing and international licensing, service companies and captive insurance companies.