Corporate tax advisory: tax choices that move with your business

Corporate tax advisory

Corporate tax advice is about the choices that can be made before transactions take place: how the group structure is set up, or the tax consequences of financing. You come up against these during reorganisations or when expanding, in the Netherlands or abroad. Before changes are made, future tax positions need thinking through, a proper risk analysis has to be carried out and matters may need to be settled with the Dutch Tax and Customs Administration.

Advice only works when it is processed correctly in the administration and the tax return. Conversely, a return can only be prepared properly when the underlying choices have been clearly communicated and well documented. That is why OneLane keeps both processes aligned.

Corporate tax advice covers subjects such as the following.

A tax structure that fits the business

A company’s structure often takes shape step by step. A holding company is set up, then a second operating company, a property company or a foreign subsidiary. Over time a group can end up consisting of entities that each had a good reason once, but no longer make sense together. A tax structure is not a final picture that stays unchanged for decades; it should be reviewed periodically as the business changes.

Holding and group structures

The legal structure, the actual activities, the contracts and the administration all have to tell the same story.

Fiscal unity for corporate income tax

Within a fiscal unity for corporate income tax, loss-making companies can offset their losses directly against the positive results of other companies in the same group in the same year, which saves tax. We assess not only whether a fiscal unity can be formed, but above all whether it still suits the group. We handle the request and the termination, and process the consequences.

Participation exemption

The participation exemption allows profit to be distributed from one company to another free of tax, so that you do not pay corporate income tax twice on the same profit. We assess the qualification in advance and record the tax position, so that it can be substantiated later in returns, financial statements and during an audit.

Loss relief

Tax losses can represent value, but only to the extent that they are usable both legally and economically. A loss on a tax balance sheet is therefore not automatically equal to a future tax saving. We also assess whether a planned decision would unexpectedly restrict the scope for loss relief.

Financing and interest deduction

Financing affects the company’s tax position. The lowest interest rate or the highest debt is not automatically the best outcome. The financing has to be legally enforceable, sound in business terms and defensible for tax purposes.

Profit distributions and capital

Profit can be moved or made available within a group in various ways. A distribution has to match the actual rights and financial position of the entities involved.

Tax restructuring

A tax-neutral reorganisation does not mean that no conditions apply. The structure also has to be monitored carefully after it has been carried out.

Mergers and demergers

Mergers and demergers can be used to bring activities together or, conversely, to separate them. Tax and legal work side by side here: a tax facility can only be used properly when the legal execution and the day-to-day running of the business line up with it.

Investment, innovation and growth

A business that invests in people, technology, sustainability or capital assets may be able to use tax facilities, each with its own specific conditions.

International expansion

When a business becomes active in another country, questions arise about the form that presence takes and its tax consequences. The cheapest route on paper is not always the best operational structure. The form you choose has to suit your customers, your staff, your decision-making and your growth plans.

Permanent establishments

A business can become liable to tax in another country without setting up a separate company there. Our corporate tax specialists work together with our transfer pricing and global mobility services teams on these questions.

Withholding taxes and international payment flows

Payments between countries can be affected by withholding tax. The route a payment takes has to match the actual ownership, functions and financing within the group.

Have your tax position reviewed

Reviewing a tax position gives you insight into the main risks and opportunities within your structure. A solution should not only be attractive for tax purposes: the organisation also has to stay manageable and flexible.

OneLane makes sure tax choices form part of better business decisions.