Tax Battle: US vs Holland

Toine Geesink: International Tax Partner Bol InternationalDoug Wright: International Tax Partner Burr Pilger Mayer

When two tribes go to war

Tax battle: US versus Holland - 2

First experience with US client

Tax battle: US versus Holland - 3

Background of different international tax policy

Tax battle: US vs Holland - 4

Dutch international focus: no choice but a necessity!

Tax battle: US vs Holland - 5

Influence on international tax system

HollandThe Dutch philosophy is that enterprises with activities abroad should be able to compete with their local competitors. Therefore they should enjoy the same tax burden:

EXEMPTION METHOD

USThe philosophy of the US is that the tax consequences of a location choice should not drive enterprises to invest outside the US (because it is cheaper there). Companies should enjoy the same tax outcome over their domestic and foreign investments:

CREDIT SYSTEM

Tax battle: US vs Holland - 6

Influence on international tax strategy

Dutch companies: Repatriate dividends as much as possible

US: Defer repatriation of dividends as long as possible (‘loophole’)

Tax battle: US vs Holland - 7

Border

Dividends

Connecting the US and Dutch tax system

At first sight it looks like two totally different tax systems that do not match (‘battle’), but it turns out we are on the same team!!

Bol - onderwerp - 8

The floor is for Doug!!