Welcome

We are Merlyn International Tax Solutions Group in Rotterdam, the Netherlands.

We advise mid-size and large multinational enterprises by assisting controllers, CFOs and tax departments with optimizing their worldwide tax positions.
Smaller enterprises may want to use our special royalty conduit concept for cross-border leasing, cross-border licensing, cross-border consulting or reinvoicing.

On this website you will be able to read about a number of both traditional -but still effective- tax strategies and the new, cutting-edge ‘tax products’ we have designed to reduce the worldwide tax burden on your company’s profits.

Despite the existence of tax treaties, double taxation of company profits is still a day to day headache for companies with cross-border operations. Countries refuse to align their tax systems with one another, as a result of which in many cases, upon cross-border transactions, tax is paid in one country without (sufficient) tax relief in another country. Major examples are: 1) losses can usually not be offset cross-border, implying considerable cash-flow disadvantages; 2) withholding taxes almost always end up as excess foreign tax credits; 3) VAT is often non-recoverable even if incurred in a pure business environment. Surprisingly. many companies involved in international business are not even fully aware of where and how they overpay taxes and by how much . If their competitors are, and do something about it, this poses a serious threat to the continuity of the first group: overpayment of taxes in comparison with competitors necessarily leads to low R&D efforts, compared to those competitors.

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1) We assist CFOs and Tax Directors of multinational enterprises to avoid double taxation on business profits;
2) We help them to reduce excessive foreign withholding taxes which cannot be (fully) credited in their home country;
3) We assist with avoidance of non-recoverable VAT;
4) We are able to provide several unique tax savings structures whereby clients use group independent Dutch legal entities, enabling them to access long lasting group tax reductions;
5) We develop tax effective new structures which will allow multinational companies to even further reduce their taxes, by using so-called ”mismatches” between the tax systems of the countries they do business in, so a tax disadvantage is turned into a tax advantage. We have delivered hybrid loans, hybrid partnerships and even hybrid permanent establishments! However, such completely legal tax planning is known to governments and the year 2016 will show, via the so-called BEPS programme of the OECD, some major changes in tax laws, tax treaties and EU tax directives. So continuing to rely on old tax planning ideas is dangerous. Tax planing requires maintenance! By using the pull down menus at the top of this page, you may go directly to any of the subjects mentioned.

Some of our tax solutions are only available to clients on a success fee basis: we design certain tax saving structures and perform all country-specific tax research by obtaining tax opinions from reputable tax firms in the relevant countries. We see to the incorporation of the legal entities needed to make the structures work and design the tax aspects of the intercompany agreements. Subsequently we implement our tax inventions in the specific client environment. Instead of charging hourly rates, we may from time to time agree with clients to pay us a percentage of the tax savings which they will achieve with our structures, as long as these structures are effective. In such cases we charge a relatively minor set-up fee in advance for these activities. However, this fee will be deductible from our success-fee payments at a pre-agreed pace.

Our tax advice and support, as well as the unique solutions we offer on a success fee basis, were developed in over thirty five years of international tax experience, both in a governmental environment, in a major international tax consultancy firm and as in-house tax counsel in industry. For a resume of our managing partner, please see the About Us section on this website…

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