Corporate Tax Advice | Netherlands, Luxembourg & Switzerland

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Tax Rulings, Compliance and Audit Defence

WVT's tax advisors engage directly with Dutch, Luxembourg, and Swiss tax authorities on advance pricing agreements and binding rulings — providing certainty before a structure is implemented. Our compliance practice covers corporate tax filings across all three jurisdictions, including group-level positions under OECD guidelines. Where a tax authority challenges a position, our attorneys and tax advisors manage the defence through audit, objection, and appeal. Multinational clients receive coordinated support rather than separate engagements per jurisdiction.

Our expertise

Cross-border legal and tax advisory for multinational corporations, PE fund managers, and family offices with operations in the Netherlands, Luxembourg, and Switzerland. WVT’s attorneys and tax advisors handle complex multi-jurisdiction mandates — from holding structure design to regulatory compliance and corporate reorganisation.

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Holding Structures and Cross-Border Tax Planning

Luxembourg and the Netherlands remain two of Europe's most widely used holding jurisdictions, and Switzerland continues to attract principal and treasury structures. WVT advises multinational groups on the selection, implementation, and ongoing maintenance of holding arrangements — taking into account treaty access, dividend withholding, and substance requirements. Our tax advisors also counsel clients on reorganisations that cross multiple jurisdictions: inversions, principal migrations, and divisional carve-outs. Each engagement draws on WVT's in-house capability across all three countries rather than relying on external referrals.

FAQ's

How does WVT coordinate corporate tax advice across multiple jurisdictions simultaneously?

WVT maintains in-house advisory capability across the Netherlands, Luxembourg, and Switzerland, which means a single engagement team handles the full cross-border mandate. Clients receive coordinated advice — legal and tax in parallel — without managing separate local firms. This structure reduces duplication, shortens execution timelines, and ensures consistency in positions taken across jurisdictions.

What is WVT's approach to obtaining advance tax rulings in the Netherlands and Luxembourg?

WVT’s tax advisors prepare and submit ruling requests directly to the Dutch Belastingdienst and the Luxembourg tax authorities on behalf of clients. The process covers advance pricing agreements, confirmation of holding regime eligibility, and hybrid instrument treatment. WVT coordinates with local authorities from the drafting stage, managing the dialogue through to binding confirmation.

How does WVT support multinationals in meeting Pillar Two compliance obligations?

WVT’s tax advisors assess a group’s exposure to the global minimum tax under Pillar Two, identify which entities fall within scope across the Netherlands, Luxembourg, and Switzerland, and advise on top-up tax positions and qualified domestic minimum top-up tax elections. WVT also supports the preparation of GloBE information returns and coordinates with group tax functions on country-by-country reporting obligations.

Can WVT advise on transfer pricing documentation across all three jurisdictions?

WVT prepares master file and local file documentation for multinational groups with operations in the Netherlands, Luxembourg, and Switzerland. Our tax advisors design intercompany pricing policies for financing arrangements, IP licences, and intra-group services — and support clients through transfer pricing audits and advance pricing agreement negotiations with the relevant authorities.

At what stage should a multinational engage WVT for corporate tax structuring advice?

Engagement at the design stage produces the best outcomes. WVT’s tax advisors are most effective when involved before an entity is incorporated, a transaction is signed, or a restructuring is initiated — allowing the group’s cross-border tax position to be optimised from the outset. WVT also advises on existing structures where a review, ruling update, or reorganisation is required.

However, obviously, WVT cannot always get involved in the design stage and most design is usually driven by third country considerations. WVT can also get involved post-implementation stage and help clients to optimize the use of such structures.