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Amicorp Netherlands
 
 
 
 
 
 
 
The Netherlands has a historic key role in international tax planning. The country offers a wide range of facilities that allow both non-resident corporate and individual clients a broad range of tax advantages. The most significant international tax features of The Netherlands include a large network of double taxation treaties which often reduce the withholding tax rates on dividends paid to Netherlands holding companies to zero. Within the European Union, the 'Parent/Subsidiary Directive' can eliminate withholding taxes on dividends and royalties transferred between resident European Union legal entities. Withholding tax on interest paid to The Netherlands are usually eliminated and withholding tax on royalties paid to The Netherlands is limited to between 0% and 5% in most cases.

For dividends paid from a Netherlands holding company to its parent company, significantly reduced withholding tax rates may also apply. Interest and royalties paid from The Netherlands are not subject to a withholding tax.

All Amicorp Group products are provided through Amicorp Netherlands. Some principal structures routed through The Netherlands include:
 
Holding Structures
 
A Netherlands intermediate holding company holds shares in a subsidiary company located outside The Netherlands. Significant reductions in the applicable Netherlands tax on income result because no Netherlands corporate income tax is levied on dividends received or on capital gains realized from the (partial) sale of shares, given certain conditions (e.g., participation exemption qualification).
 
Finance Structures
 
Intra-group financing (i.e., internal leveraging) can be achieved through an intermediate Netherlands finance company. This company borrows monies from internal and/or external sources for re-lending to its lower tiered group companies. Netherlands taxes on the interest received and paid with respect to the loans can frequently be reduced to nearly zero as interest paid can be deducted from interest received. Only a (small) spread is regarded as taxable income in The Netherlands.
 
Royalty Structures
 
The cross-border flow of royalties can be structured through a Netherlands royalty company. The company holding (i.e., owning) the intellectual property grants a license to use the rights (e.g., such as copyrights for movies, images and certain industrial property rights to trademarks and patents). The Netherlands Company sub-licenses these rights to other companies worldwide. Royalties paid (without withholding tax) can be deducted from royalties received, leaving only a small taxable spread in Netherlands.
 
Real Estate Structures
 
Holding of Real Estate is often structured through a Netherlands double entity (parent-subsidiary) structure. In this structure, real estate is both held and managed by The Netherlands subsidiary. When the real estate is to be sold, the shares of the Netherlands subsidiary (holding the real estate) are sold. Proceeds from the shares sold in the subsidiary are tax-exempt in the holding company due to participation exemption.
 
Consultancy and Agency Structures
 
A Netherlands company may also be used for either trading activities or the provision of services (e.g., consultancy). This company enters into a service or representation agreement with a low-tax jurisdiction company. Under the agreement, the Netherlands Company performs certain activities at the risk and for the account of the low-tax jurisdiction company. The Netherlands Company may purchase and sell goods and pay the profit of the trade to the low-tax jurisdiction company after the deduction of an agency fee. The Netherlands Company may also render certain services (in exchange for a fee) or engage another party to obtain/perform, for a fee, the same type of services. The resulting profit spread can be paid to the low-tax jurisdiction company following the payment of a consultancy fee.
br>All Netherlands services can be provided by establishing and managing companies either directly owned by the client or through an in-house structure controlled and managed by Amicorp on behalf of multiple clients.

Languages spoken: Dutch, Spanish and English.
 
 
 
Amicorp
Netherlands B.V.
WTC Amsterdam,
Tower C-11
Strawinskylaan 1143
1077 XX Amsterdam
The Netherlands
 
Tel.: +31 20 578 8388
Fax.: +31 20 578 8389
 
E-mail:
 
 
 
 
   
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