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New partnership rules set to take effect in 2025 may subject regulated funds using tax-transparent Dutch Commanditaire Vennootschap (CV) structures to Dutch corporate income tax (CIT) and dividend withholding tax (DWT). The CV is a frequently used partnership vehicle to structure regulated funds and associated feeder/investment entities. 

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Photo of Thomas van der Vliet Thomas van der Vliet

Thomas van der Vliet is an attorney-at-law focused on Dutch and international tax advice and litigation for domestic and cross-border M&A projects and corporate restructurings. Thomas has wide-rangiong experience in EU tax law and the application of tax treaties. Additionally, he advises various

Thomas van der Vliet is an attorney-at-law focused on Dutch and international tax advice and litigation for domestic and cross-border M&A projects and corporate restructurings. Thomas has wide-rangiong experience in EU tax law and the application of tax treaties. Additionally, he advises various types of funds, including investment and private equity funds, on their Dutch and international tax positions. Thomas currently serves as Chair of the firm’s Amsterdam office and Co-Chair of its Global Tax Practice.

Concentrations

  • International tax advice, with focus on transatlantic structures
  • Transactional services (due diligence, M&A structuring, post-acquisition reorganizations)
  • Litigation in both tax and civil courts
  • Transfer pricing
  • Tax compliance
Photo of Richelle Baptiste ˘ Richelle Baptiste ˘

Richelle Baptiste is a senior tax lawyer and has great experience in national and international tax planning structures. She has deep knowledge of complex cross-border tax structures, IP structures, litigation in tax related matters, and M&A projects. Richelle has advised on a wide…

Richelle Baptiste is a senior tax lawyer and has great experience in national and international tax planning structures. She has deep knowledge of complex cross-border tax structures, IP structures, litigation in tax related matters, and M&A projects. Richelle has advised on a wide range of corporate transactions and tax treaty analysis in cross border projects.

˘ Admitted to the Dutch Association of Tax Advisors Bar.

Photo of Thomas de Booij Thomas de Booij

Thomas is a senior associate in the Amsterdam tax practice. He primarily focuses on Dutch and international taxation, covering both the traditional and digital economies. His experience encompasses (family-owned) investment funds, scale-ups, and large multinationals in the energy and shipping sectors. Thomas has…

Thomas is a senior associate in the Amsterdam tax practice. He primarily focuses on Dutch and international taxation, covering both the traditional and digital economies. His experience encompasses (family-owned) investment funds, scale-ups, and large multinationals in the energy and shipping sectors. Thomas has experience with European market entries for various types of companies with businesses ranging from engineering services to tech-based platforms.