Presentation at Seminar Doing Business: NL vs USA (2012 April 19, Amsterdam) Organised by: - Leading Edge Alliance - Bol International - Van Oers International

1. Tax Battle: US vs Holland
Toine Geesink: International Tax Partner Bol International
Doug Wright: International Tax Partner Burr Pilger Mayer

2. When two tribes go to war
Tax battle: US versus Holland - 2

3. First experience with US client
Tax battle: US versus Holland - 3

4. Background of different international tax policy
Tax battle: US vs Holland - 4

5. Dutch international focus: no choice but a necessity!
Tax battle: US vs Holland - 5

6. Influence on international tax system
Holland
The 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
US
The 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

7. Influence on international tax strategy
Dutch companies: Repatriate dividends as much as possible
US: Defer repatriation of dividends as long as possible (‘loophole’)
Border
Dividends
Tax battle: US vs Holland - 7

8. 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

9. The floor is for Doug!!