Frank has a strong reputation as problem solver, both in relation to litigation and potential discussions with the tax authorities. His unique approach to litigation has made him a sought-after consultant for other advisors on strategic, technical and tactical issues in court proceedings. Frank has extensive knowledge of tax governance issues, including beneficial ownership and the treatment of ultimate beneficial owners (UBOs). He is one of the best-known tax litigators in the Netherlands.

Experience

Frank is a founding partner of two tax firms: Herreveld & Van den Hurk and HVSTAX. He has extensive experience with tax litigation before the Dutch district tax courts, courts of appeal and the Dutch Supreme Court. Furthermore, he litigated tax cases at the European Court of Justice and the European Court of Human Rights. 

Academic

Frank has been a member of the editorial board on the Weekblad fiscaal recht in 1985. He has published numerous articles, including Nederlands Tijdschrift voor Fiscaal Recht and NLFiscaal. He also lectures at Leiden University and Maastricht University, where he teaches procedural tax law and assumes the role of judge in Moot Court.

Frank chairs the Dutch Association of Tax Advisors expert committees on preliminary questions and is the former chair of the committee on procedural law. He is responsible for the mandatory module on procedural tax law in the professional training programme of the Dutch Association of Tax Advisors.

Expertise

• Litigation and dispute resolution
• Opinions and second opinions
• Transfer of IP
• Transfer pricing issues
• Interpretation of interest deduction limitations
• Participation exemption and deductibility of foreign losses
• Applicability of the fair play doctrine for tax authorities
• Recovery of State Aid
• Introduction of new taxes

Affiliations

• The Netherlands Bar (Nederlandse orde van advocaten, NOvA)
• Dutch Association for Tax Scholarship (Vereniging voor Belastingwetenschap)
• Dutch Association of Tax Advisors (Nederlandse Orde van Belastingadviseurs)

Recent publications

• Pillar 2 Lex Imperfecta, Weekblad fiscaal recht 2024. (article in journal, together with Van den Hurk)
• Strengthening legal protection in tax law, Liber Amicorum in Honour of Prof Essers, 2024. (book chapter)
• How to combat excessive no-cure-no-pay abuse of procedural tax law, 2023. (article in journal)

Please contact Frank Herreveld if you have any questions or would like to receive a copy of one of the publications.