Contact our Corporate & International expert

Gertjan Hesselberth
Partner

Partner
As a CFO or Tax Manager of an internationally operating company, you know that tax regulations are becoming increasingly complex. From anti-abuse rules to substance requirements - the tax world is evolving rapidly. Borgen Tax offers you the expertise and experience to navigate through this complexity. Our practical approach and direct advice ensure that you take the right tax positions and manage risks.
Corporate & International Tax at our firm encompasses the broad corporate tax practice for medium and large companies. It covers all tax aspects of business operations, from compliance to strategic planning. For international companies, professional tax guidance is crucial to:
The tax world is becoming increasingly complex. Where pragmatic solutions used to be possible, today's regulations require thorough preparation and strategic planning.

Clear tax advice with practical steps, directly applicable through years of hands-on experience.

You will work directly with our experienced partners who dare to guide you in making decisions and conduct proceedings against the tax authorities on your behalf.

Through our Taxand network, we assist with both tax and civil aspects of complex transactions in 50+ countries.
VPB returns
Complete assistance in the preparation of corporate tax returns, from individual entities to complex tax units. We offer different service levels: full tax return support, complex sections, or review of your internal preparations.
Interest deduction limitation and anti-abuse rules
Strategic advice on interest deduction limitations, ATAD implementation and other anti-abuse measures. We ensure that you meet all compliance requirements without unnecessary tax burden.
Substance requirements and documentation
Support in meeting substance requirements for internationally operating companies. We advise on required documentation and operational interpretation to secure tax positions.
International expansion and branches
Guidance on setting up foreign branches or receiving foreign investment in the Netherlands. We navigate through set-up risks and optimize your business internationally.
Reorganizations and restructurings
Tax support for internal reorganizations, IP transfers and function changes within international groups. We ensure correct valuation and manageable tax burdens during restructurings.
Participation exemption and dividend optimization
Strategic planning around the participation exemption, withholding exemptions and optimal dividend structures within your international organization.
Tax Proceedings
Professional representation in proceedings against the tax authorities. We dare to take positions and guide you through the entire process, from objection to appeal and cassation.
Preventive measures
Proactive advice to prevent disputes through timely documentation and correct position-taking. We know the formal side of the game and ensure strong legal positions.
Risk management
Identification and management of tax risks in complex international structures. We advise on tax insurance and where relevant and develop risk management strategies.
01
We begin with a thorough analysis of your tax position, international structure and compliance requirements, focusing on your business goals and risk profile.
Thorough analysis and compliance check
Proactive, clear recommendations
Strategy focused on growth and security
02
We practically implement measures with full documentation, ensure proper implementation and compliance, and take complex tax implementation completely off your hands.
Proper implementation and compliance
Full documentation provided
Implementation of international structures & procedures
03
We provide ongoing guidance on changing rules and circumstances, monitor tax risks and advise proactively so that you remain prepared for any development.
Monitoring regulations and trends
Proactive advice on risks
Long-term partner who anticipates
Discover how we helped a multinational enterprise optimise group-wide liquidity through a physical multi-region cash pool. Expert guidance on arm’s length substantiation, benchmarking, legal implementation, policy design, and stakeholder alignment to ensure OECD-compliant transfer pricing and sustainable liquidity management.

Corporate & International Tax
A permanent establishment is a permanent business operation in a country without separate legal personality. This has different tax and compliance implications than a local subsidiary.
Substance requirements require that international structures have economic reality: personnel, office space, local decision-making. These apply especially when using treaty benefits and exemptions.
Anti-abuse rules apply to constructions that primarily seek tax benefits with no economic rationale. The tax authorities look at economic reality, not just legal form.
Yes, but within stricter frameworks. Modern tax planning requires real business rationale and substance. We help you develop efficient structures that combine compliance and optimization.
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