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Financial administration & outsourcing
Entrepreneurs who outsource financial administration reduce the number of administrative tasks and consequently have more time and space to focus on growth.
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Financial insight
We help you turn financial data into valuable insights that support you in making well-founded decisions. In-depth analyses of your financial situation will help give you a better idea of where you stand and where the opportunities for growth lie, both in the short and long term.
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Financial compliance
We make sure your company complies with financial legislation and regulations, with correct financial statements, tax reports and other obligations. From our global network, we support you in managing local and international tax risks.
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Impact House by Grant Thornton
Building sustainability and social impact. That sounds good. But how do you go about it in the complex world of stakeholders, regulations and frameworks and changing demands from clients and society? How do you deal with important issues such as climate change and biodiversity loss?
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Business risk services
Minimize risk, maximize predictability, and execution Good insights help you look further ahead and adapt faster. Whether you require outsourced or co-procured internal audit services and expertise to address a specific technology, cyber or regulatory challenge, we provide a turnkey and reliable solution.
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Cyber risk services
What should I be doing first if my data has been kidnapped? Have I taken the right precautions for protecting my data or am I putting too much effort into just one of the risks? And how do I quickly detect intruders on my network? Good questions! We help you to answer these questions.
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Deal advisory
What will the net proceeds be after the sale? How do I optimise the selling price of my business or the price of one of my business activities?
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Forensic & integrity services
Do you require a fact finding investigation to help assess irregularities? Is it necessary to ascertain facts for litigation purposes?
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Valuations
Independent and objective valuations tailored for mergers, acquisitions, and legal matters.
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Auditing of annual accounts
You are answerable to others, such as shareholders and other stakeholders, with regard to your financial affairs. Financial information must therefore be reliable. What is more, you want to know how far you are progressing towards achieving your goals and what risks may apply.
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IFRS services
Financial reporting in accordance with IFRS is a complex matter. Nowadays, an increasing number of international companies are becoming aware of the rules. But how do you apply them in practice?
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ISAE & SOC Reporting
Our ISAE & SOC Reporting services provide independent and objective reports on the design, implementation and operational effectiveness of controls at service organizations.
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National tax advice
Looking for tax advice in the Netherlands? We help business owners with tailor-made tax advice: from structure and compliance to innovation and sustainability.
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International tax advice
Plan to do business abroad? Our international tax advice helps you with structure and compliance, as well as offering new opportunities. Strategic, practical, and future-oriented.
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Private wealth services
Our Private Wealth specialists offer strategic and practical solutions. From tax advice to estate planning and financial scenarios, we make sure you make the right choices today, for tomorrow.
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Corporate Law
From the general terms and conditions to the legal strategy, these matters need to be watertight. This provides assurance, and therefore peace of mind and room for growth. We will be pro-active and pragmatic in thinking along with you. We always like to look ahead and go the extra mile.
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Employment Law
What obligations do you have with an employee on sick leave? How do you go about a reorganisation? As an entrepreneur, you want clear answers and practical solutions to your employment law questions. At Grant Thornton, we are there for you with clear advice, from contracts and terms of employment to complex matters such as dismissal or reorganisation.
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Sustainable legal
At Grant Thornton, we help companies integrate sustainability into their business operations, with sustainable legal at the heart of our approach. We advise on ESG (Environmental, Social, Governance) legislation, and help draft sustainable contracts, implement HR policies, and carry out ESG due diligence in M&A transactions (Mergers and Acquisitions).
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HR Services
HR is not an aspect of secondary relevance, rather a strategic factor for success. Yet many organisations struggle with issues regarding personnel policy, absenteeism, terms of employment and legislation and regulations.
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Payroll & wage tax
Payment of salaries is not a simple calculation. Laws and regulations constantly change, and mistakes can quickly cause employees to be dissatisfied or lead to tax risks.
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Compensation and benefits
The labour market is changing rapidly. Employees want flexibility, a sense of purpose and a good mixture of financial and non-financial benefits.
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Pension advisory services
Pension is more than an obligation. It is a strategic term of employment that touches upon your employer brand, financial scope and responsibility to provide for your employees.
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Global mobility services
How can you build and evolve a smart global mobility strategy, with policies and processes addressing the complex challenges of managing an international workforce?
On 1 January 2020, the Dutch implementation of the second EU directive against tax avoidance ("ATAD 2") entered into force for tax years starting on or after that date. The reverse hybrid rule took effect on 1 January 2022.
Hybrid mismatches
The following hybrid mismatches fall within the scope of the ATAD 2 legislation:
- hybrid entities;
- hybrid financial instruments;
- hybrid permanent establishments;
- hybrid transfers;
- Imported hybrid mismatches; and
- situations where there is a dual residency.
Consequence hybrid mismatch
ATAD 2 aims in principle to neutralize hybrid mismatches that result in mismatches between related entities (situations with a double deduction or a deduction without a corresponding inclusion). To neutralize these mismatches, there is a primary rule that provides that the deduction of a payment is not allowed in the state of the payer (the "primary rule"). In addition, under ATAD 2, a secondary rule may apply if the primary rule cannot be applied. The secondary rule provides that the payment is included in the taxable income of the state of the recipient of the payment (the "secondary rule"). The Netherlands has implemented the primary and secondary rule in Dutch legislation.
These rules apply in affiliated relationships or when a "structured arrangement" is present. Affiliation occurs when there is an (in)direct shareholding of 25% or more.
Reverse hybrid rule
An entity is considered a reverse hybrid entity if it is incorporated, entered into, or incorporated in accordance with Dutch law or established in the Netherlands and qualifies as transparent from a Dutch tax perspective. In addition, at least 50% of the voting rights, capital interests, or profit rights must be held - directly or indirectly - by related entities in a jurisdiction that qualifies the entity as non-transparent. A related entity is deemed to be present when there is at least a 25% interest in the hybrid entity.
Documentation requirement
The purpose of the documentation requirement is to enable the Dutch tax authorities to assess whether the ATAD 2 rules, as applied by the Netherlands, are correctly included in the Dutch corporate income tax return. The proposal does not provide any clear guidance on how the information should be documented. The following information can be used to substantiate that the documentation requirement should be met:
- Group structure;
- Intercompany agreements;
- Foreign tax returns and assessments;
- An advice or opinion from an expert in international tax law.
Taxpayers must provide this information upon request by the Dutch tax authorities within a reasonable period of time. This reasonable period is generally six weeks.
ATAD 2 tool
Based on our knowledge and experience, we have developed our own ATAD 2 documentation tool to help you with this documentation requirement. Based on this tool, we can generate an efficient, clear, and comprehensive ATAD 2 report that meets all the requirements.
We refer to the video below if you are interested in this ATAD 2 tool.
Grant Thornton closing remarks
It is advisable to review the impact of ATAD 2 on your existing structures, including CV-BV structures and (CV-)holding structures. We also advise you to ensure that the relevant documentation is available in your records. Our international tax team is ready to provide you with tax advice on the applicability of ATAD2 and to prepare the required ATAD 2 documentation.
