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DR FREEK
PJ SNEL
Dr. F.P.J. (Freek) Snel (Amsterdam 1967) has a master in Dutch law and tax law from Maastricht University. Later he completed European Fiscal Studies at the Erasmus University in Rotterdam. In 2005 he defended his PhD thesis ‘Van moeders en dochters’ (on parents and subsidiaries), at the University of Amsterdam. He is recognized as expert in the field of participation exemption/holding regimes.
He started in 1994 as tax advisor with Loyens & Volkmaars. In 1997 and 1998 he worked on an exchange basis with Cuatrecasas in Barcelona, Spain. In 2008 he moved to Houthoff Buruma, Amsterdam.
He founded SNEL Corporate Tax & Law, a tax boutique, in 2011. He is editor of the online encyclopedia NDFR – international tax and dividend withholding tax. He lectures corporate taxation at Groningen University and European tax law at the Instituto de Empresa in Madrid. He regularly gives other lectures and is the author of over 40 articles on various tax subjects.
He is member of Nederlandse Orde van Belastingadviseurs (Dutch tax bar), de Vereniging voor Belastingwetenschap (Dutch tax science asociation) en de Vereniging voor Internationaal Belastingrecht (Dutch IFA branche).
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EDUCATIONCurrently reading for his PHD at the University of Amsterdam; 2001 Masters International Tax Law (University of Leiden) Masters, International business law (University of Amsterdam, 1995); LLB Suma Cum Lauda (University of Manchester, 1994).
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LANGUAGESDutch, English and Hebrew
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SELECTED REPRESENTATIONSInitial Public offering of Plaza Centers N.V. on the London Stock Exchange; Benfield Group Ltd. In its USD 1.75 million merger with AON Private Equity Team of ABN AMRO on its Spinout from ABN AMRO N.V. Platinum Equity in connection with the sale of the Geesink Norba Group to the mutares AG group. Medco in connection with its merger with Express Scripts. Capita Asset Services (Ireland) Limited and Capita Asset Services (UK) Limited in the Fleet Street Finance Two PLC CMBS transaction. The transaction involved the restructuring of a commercial mortgage loan secured by over one hundred retail assets located throughout Germany and leased to the Karstadt department store. This transaction was the first European CMBS deal to extend the maturity date on the CMBS notes. Value EUR 538 million.
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PUBLICATIONSThe revised Permanent Establishment Rules: Intertax Vol. 31 Issue 4, p.131 – 147. National Reporter: High Level Tax Conference Held By Prof Michael Lang, Austria (Publication By Prof. Lang). Co Author, Comparative Survey on the Tax Treatment of General Enterprise – Permanent Establishment’s Dealings: (IBFD Publications) CFC legislation, tax treaties and EC Law – National Report Israel, p. 323, Edited by M. Lang et al., Eucotax, Kluwer Law International. The Evolution of Art. 4(3) OECD MC and it impact on the Place of Effective Management Tie Breaker Rule, Intertax Vol. 32, Issue 10, p. 460 – 476 Interaction between the participation exemption and the principle of Compartmentalization: Portfolio Investments in the New EU Accession Member States, European Taxation, Vol. 45, 2005, No. 2, p. 64 – 71 Luxembourg-Israel Tax Treaty Could End Notional Credit, published in the 23 December 2004 edition of the online Worldwide Tax Daily. The “tie-breaker” rule and selected issues of non-discrimination. IBFD Doctoral Series (Forthcoming) Dutch tax aspects of private class action law suits – IBFD Bulletin
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