We design robust international corporate, investment, shipping, financing and cash pool structures, allowing for efficient repatriation. Focus areas include substance, withholding taxes, participation exemption, CFC, Pillar 2 and interest deductions.

The transfer pricing models that we design align the business reality with the financial, legal and tax situation. This includes substance / DEMPE design and international IP structuring. We document the transfer prices in OECD-compliant Master and Local Files.

Our aim is to help clients sustain a good relationship with the tax authorities. We assist in setting up tax control frameworks and manage DAC6. We guide clients through during tax audits, ruling negotiations (APA/ATR) and, if needed, tax litigation and MAP procedures.

We support our clients with mergers, acquisitions, divestments, joint ventures and IPOs. Our assistance covers the due diligence process, transaction documentation, tax structuring and post-transaction integration.

OHP has a specific focus on US, German and Chinese companies and investors that are active in the Netherlands. One of the partners is fluent in German and has worked in New York. For our Asian clients, we have a dedicated China desk.

When advising our clients on international tax and transfer pricing matters, regularly, VAT and wage tax questions pop up. OHP assists clients with these matters and works with a trusted network of excellent tax advisors.