Hilmar Nierop obtained his LL.M. degree in Dutch civil law at Leiden University in 1986, with tax law and corporate law as majors. After graduating, he started work as a tax consultant. He later expanded his professional scope to the broader financial and corporate services sectors and dealt with various specific issues, relevant at that time.

Hilmar has fulfilled both operational (problem solving, projects) and managerial roles (execution & team focused). He has experience in governance (policies & procedures, including tax good governance, and the three-lines-model) and consulting (regulatory audits and investigations). In recent years, he also worked on GRC projects, mostly on a part-time and/or freelance basis.

Experience

Hilmar is a specialist in tax substance reviews. These reviews are always based on existing fact patterns, i.e. do not provide advice for tax planning. Hilmar can assist clients with the identification, quantification and documentation of activities in different jurisdictions, in the context of litigation. Tax substance reviews can be helpful in the event of disputes regarding beneficial ownership and anti-abuse rules based on substance. Hilmar combines economic analysis with an analysis of the relevant regulatory environment, adding an extra dimension to a client’s transfer pricing documentation.

In addition to the tax substance reviews, Hilmar can help address the impact of the EU rules on ESG and CSRD (double-materiality) and of sustainability performance targets. Hilmar also advises Dutch regulated entities (e.g. banks, trust services providers, tax advisors, lawyers, accountants regulated parties) on ‘customer tax integrity risk management’ and prepares client-specific substance reviews.

Expertise

• GRC (Governance, Risk, Compliance)
• Tax substance consults, audits and investigations
• Customer tax integrity risk management and client-specific reporting

Please contact Hilmar Nierop if you would like to receive more information.