Blue Clue Tax Solutions

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Fiscal economics, Erasmus University Rotterdam
Baker Tilly Berk (91-92), PwC (92-97), Horlings (97-10)
International

Fiscal economics, Erasmus University Rotterdam Baker Tilly Berk (91-92), PwC (92-97), Horlings
tax partner (99 – 10)
Board member of Horlings (06 - 09)
2011: Founder of Blue Clue Tax Solutions
Focus: International services
Contact details: tkrol@blueclue.nl

Ton Krol: tax advisor for international clients

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The Netherlands, Gateway to Europe (2018v1)

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Fiscal law, Leiden University
Deloitte (96 – 11), C-Corp (11– 13)
International tax director

Fiscal law, Leiden University Deloitte (96 – 11), C-Corp (11– 13) International
(11 – 13)
2013: Partner of Blue Clue
Focus: International services
Contact details: mhertog@blueclue.nl

Marc Fruyt van Hertog: tax advisor for international clients

11/28/18 -

The Netherlands, Gateway to Europe (2018v1)

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Cool tax practice with high level of expertise
Advice, Litigation, Tax compliance, Corporate

Cool tax practice with high level of expertise Advice, Litigation, Tax compliance,
Services
Specialization: international clients
NLs as hub into Europe
Local sales team, customer support
Distribution, trade: import/export
Holding, finance
Mergers & Acquisitions
Startup in NLs
Expats
Tailored solutions for clients
Solutions for international businesses and HNWI

Who are we: Blue Clue

The Netherlands: Gateway to Europe (2018v1)

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The Netherlands (as Gateway)

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The Netherlands: Gateway to Europe (2018v1)

The Netherlands (as Gateway) 11/28/18 - The Netherlands: Gateway to Europe (2018v1)

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"INTERNATIONAL BIG BUSINESS’ PREFER INVESTING IN THE NETHERLANDS, COMPARED WITH OTHER EUROPEAN

"INTERNATIONAL BIG BUSINESS’ PREFER INVESTING IN THE NETHERLANDS, COMPARED WITH OTHER EUROPEAN
COUNTRIES”
because of:
Pro-business and pro-commerce attitude
Well educated workforce
Effective tax rates
Economical and political stability
Quality of life

The Netherlands: Gateway to Europe

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The Netherlands: Gateway to Europe (2018v1)

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Business: trade / logistics / IT services
Lower withholding tax rates
Safe haven: investment

Business: trade / logistics / IT services Lower withholding tax rates Safe
treaties
Representation office (no Dutch corporation tax)
Branch: registration Ukraine company in Netherlands
Dutch company: BV (Ltd), NV (Corp.), Coop, Stichting (Foundation/STAK)
Funding / operational cash flow: equity, loan, hybrid
VAT liability?
Substance?
Bank account: know your client / source of funds
Work/residence permit?

Structuring: what are you going to do?

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The Netherlands: Gateway to Europe (2018v1)

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Immigration office: IND
EU citizens: no visa
Permits:
Regular employee
Highly skilled migrants
Registered HSM sponsors
Self

Immigration office: IND EU citizens: no visa Permits: Regular employee Highly skilled
employed
Business plan to be approved by Netherlands Enterprise Agency (in Dutch: RVO)
Added value for the Netherlands ≈ economically viable
Freelancers: one or more paid assignments
Startups
Innovative product or service
Completed step-by-step plan
Registered startup facilitator, like: Crosspring

Tax: visa

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The Netherlands: Gateway to Europe (2018v1)

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Back to Back structures: non-related Dutch party
Equipment: Import – Modification / Assembly

Back to Back structures: non-related Dutch party Equipment: Import – Modification /
– Export
Financing
Invoicing
HNWI: car lease
Online services B2C / B2B
Car manufacturer: transfer EU staff to Netherlands
EMEA Sales and (After sales) Support teams

Practical cases

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The Netherlands: Gateway to Europe (2018v1)