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One minute with...Peter Adriaansen

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You are a tax partner at the Loyens & Loeff London office. What’s in your in-tray?

My team advises on Dutch and Luxembourg tax law, working closely together with our corporate, banking and investment management colleagues in the London office. At present, we are working on: the set-up of a debt investment platform in Luxembourg for a UK pension fund, the transfer of all the IP of a NYSE listed group to the Netherlands and one of the pending state aid investigations.

What sets Loyens & Loeff apart from other law firms?

What sets us apart on the tax side is the breadth of our tax practice, working together closely with all the other practice groups. It is great to work in a firm with well over 300 tax colleagues, spread over our ‘home’ offices in The Netherlands, Belgium, Luxembourg and Switzerland. This gives us edge helping clients deal with all the rapid changes taking place in the world of international tax.

Looking back on your career to date, what key lesson have you learned?

Never stop meeting the people you work with face to face. Even though our daily working life mostly consists of contact via conference calls and emails, at the end of the day what we do is help people deal with the issues they need to deal with.

What’s the number one practical issue on tax for your clients?

BEPS and all the changes to domestic laws, transfer pricing guidelines and tax treaties this will trigger. Every client will need to deal with this.

The European Commission recently announced its final decisions in the Fiat and Starbucks cases. What is the likely impact on international tax issues?

The European Commission takes a strong stance on transfer pricing and seems to apply its own arm’s length principle, regardless of whether and how a member state has incorporated the arm’s length principle into its own tax system. Although the positions taken by the Commission still need to be tested by the CJEU, this could have far reaching consequences: every advance pricing agreement or other compromise on a transfer pricing issue would have to fit the Commission’s own arm’s length principle.

How do you expect Luxembourg to reform its tax system?

Luxembourg will try and adapt its tax system to the changing global and European tax environment, at the same time trying to stay competitive to retain and attract investment. A currently pending bill of law includes some amendments to its net wealth tax for companies and a very interesting broadening of the scope of the existing exit tax payment deferral available to migrations and transfers to treaty countries. However, Luxembourg will need to do much more. In the coming months, Luxembourg will present its plans for a broader tax reform, which should hopefully include a rate reduction.

Tell us a secret.

The London office is the fifth Loyens & Loeff office I have the pleasure of working at. Having started my career at the Ministry of Finance in The Hague, I joined the firm in the Rotterdam office. Since then, I have worked in our Brussels, Tokyo and Luxembourg office before joining our London office two years ago