Merlyn International Tax Solutions Group primarily focuses on a combination of two areas of support to multinationally operating clients which are not part of the services of any other tax advisory group:

  1. A) we provide international tax advice which employs different types of tax savings than the big international accounting- and law firms. This is because our business model differs from these other advisers;
  2. B) we assist clients in achieving their tax goals, by demonstrating that Dutch legal entities, owned by Dutch fiduciary services providers, perform better than traditional royalty conduit structures because intercompany transactions will then become third party transactions.

This approach has led to a number of specific services that others do not provide. Please note that the term ”royalties” in a tax sense is much wider than its legal counterpart.

Cross-border leasingand consulting also give rise to royalty payments in a tax sense, just like cross-border license fee payments;management fee charges and technical services too, just like transfer of technical know-how;

  1. New hybrid entity and hybrid permanent establishment tax planning opportunities;
  2. Capital gains tax reduction structures for real estate investments, worldwide.

All structures we advise are fully legal. We focus on investors from whatever foreign country, seeking to invest in another foreign country. For example, Canadian multinationals seeking to do business in China, or US-based multinationals seeking to do business in Eastern-Europe, or in South-Africa etc. Our advice will show them how they can reap substantial tax benefits from routing their investments through the Netherlands. Due to the OECD BEPS programme, such tax driven structures require maintenance: 2015 will show many changes to the existing tax laws and tax treaties in force today (January 2015) and even changes to EU tax directives.

Our advice is based on 35 years of practical experience, gained by our managing partner in his professional career, starting in 1978, which has consisted of several governmental tax positions, many years of international tax consultancy in one of the Big Four audit and tax firms, an industry tax directorship in the IT sector and – since 1-1-2004 – the running of the Merlyn International Tax Solutions group. He combines his knowledge of these different sectors to create unique, but also practical, international tax savings opportunities.

On most of the above subjects, we have written articles in reputable tax and finance magazines, to be found in the Publications section of this website. The developments in the BEPS programme have his full attention to spot pitfalls but also new tax planning opportunities.