Welcome. You have reached the website of the Merlyn Tax Solutions & Fiduciary Services group in Rotterdam, the Netherlands. 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.
We advise mid-size and large multinational enterprises, where we assist controllers, CFO's and tax departments with optimising their worldwide tax positions. Smaller enterprises may want to use our proprietary royalty conduit concept, for cross-border leasing, cross-border licensing, cross-border consulting or other forms of reinvoicing.
Avoidance of Double Taxation
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, etc. Many companies involved in international business are not even aware of where and how they overpay taxes. 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.
Mission Statement
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 Dutch legal entities, owned and managed by us, 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 deliver hybrid loans, hybrid partnerships and even hybrid permanent establishments!
No Cure No Pay basis
Some of our tax solutions are only available to clients on a success fee basis: we design certain tax saving structures and do all country-specific tax research by obtaining tax opinions from reputable tax firms in the relevant countries, free of charge. We incorporate the legal entities needed to make the structures work and design the intercompany agreements, for our own account. Subsequently we implement our tax inventions in the specific client environment. Instead of charging hourly rates, we agree with clients to pay us a percentage of the tax savings which they will achieve with our structures, as long as these are effective.
Our tax advice and support, as well as the unique solutions we offer on a success fee basis, were developed in over thirty 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. See also www.jos.peters.nl for a backgound on our MD, mr. Joseph Peters MBA
