Marco Zimmerman Director

Personal quote / vision

I advise my clients on the correct application of payroll tax and social insurance rules. When doing so, I do not only give advice, but also investigate the possibilities to optimise the client's situation or limit risks. In addition, I focus on advising on international secondment, the withholding obligation of foreign employers and the possibilities of tax-free reimbursement of extraterritorial costs.

Specialist experience

My experience is on application of hardcore payroll tax topics such as:

• Tax assessment of employment conditions
• Cafeteria regulations
• Working Costs Regulation (WKR)
• Assessment of employment relationships (self-employed, etc.)
• DGA issues (insurance obligation, customary pay, management agreement) etc.
• Wage cost benefits payroll administration
• WKA (hirer's liability, vicarious liability, directors' liability)

But also on cross-border employment involving topics such as:

• Application of tax treaties (in which country do you have to pay tax when working across the border)
• Assessment of insurance obligations (in which country are you socially insured and where do you paycontributions or not)
• Labour law aspects
• Salary split
• Ins and outs surrounding the A1 declaration, Rhine boaters, etc.

Specific client experience

• In my role as tax consultant, I assist temporary employment agencies, payroll companies and other companies that provide personnel. I also advise employers in the not for profit sector.

Education and work experience 

In my role as tax adviser, I assist employment agencies, payroll companies and other companies that provide staff (or indeed the hirer of those staff), among others. I also advise employers in the not-for-profit sector.

For the last 12 years, I have focused on companies and organisations working with a flexible shell.
I work a lot and enjoy working for temporary employment agencies, secondment agencies and other intermediaries that provide labour to clients. This often involves temporary workers, but in recent years, also self-employed workers.

I advise on the following subjects, among others:

• Application of the ET scheme
• Substantiating net reimbursements
• The company car (fleet of temporary employees) and the fiscal addition
• Working expenses scheme
• Secondment abroad (e.g. Belgium or Germany with their own rules)
• 30% rule
• Highly skilled migrants scheme, third-country nationals
• Borrowing and on-lending
• G account
• Intermediation of self-employed persons (via intermediation or pure mediation). Super topical given the abolition of the enforcement moratorium (DBA Act), proposals for the VBAR Act, WTTA, etc.

I am also regularly asked to assist employers in case the tax authorities announce a payroll tax audit or get stuck in it (preparing, supervising the investigation, limiting financial losses, making agreements, etc). It is good to be prepared for this and to take risk-mitigating measures in advance; this can be done by having good procedures and applying them in practice (tax control framework, general or on specific subjects such as the WKR, declaration system, company car). Often these tax audits focus on all aspects of payroll taxes, sometimes it is a partial audit for a specific subject. It may also involve an investigation in response to a request submitted to unblock the G account.

Besides tax audits, I also assist companies with NEN audits, SNCU audits, pension audits (StiPP, PMT, PME, ea), Labour Inspectorate, IND.

In the standards book of the SNA, you see more and more specific rules being included that are checked during the NEN audit and still sometimes cause problems. I would mention foreign self-employed workers, the ET scheme, hiring and on-lending with A1 certificates, etc. The NEN certificate is becoming increasingly important, especially given the upcoming introduction of the WTTA, the new admission system for companies supplying or hiring workers.

Another current topic on which I advise a lot is the assessment of employment relationships of ZZP-ers and the employment issue in the context of the DBA Act (Deregulering Beoordeling Arbeidsrelaties) and expected new legislation. Both for clients and for contractors, I assess contracts for aspects that may indicate the existence of an employment relationship and advise how the agreement and/or cooperation should be adjusted to avoid running any risks. An important part of this is also the drafting of control measures (kind of tax control framework, TCF).

Other issues I regularly advise on are:

• Certification NEN 4400-1 and 4400-2
• Salary split situations
• Posted workers notification, notification
• Assisting with unblocking investigations by the tax authorities (G account)
• Supervise ordinary tax audits
• Supervise completion of SNCU audits (collective labour agreement and StiPP)
• Preventing additional final taxation on severance payments (RVU levy) or excessive severance payments
• Working Costs Regulation (WKR)
• WKA: chain liability and hirer's liability (how can you prevent this risk?)
• Act to tackle fraud (WAS)
• Work Market in Balance Act (WAB)

Education and work experience

After studying tax law in Leiden, I started as an all-round tax consultant 30 years ago, but soon decided to specialise in payroll taxes. I am still happy with that choice because you can really help clients further with your specialist knowledge and experience.

• 1989 - 1995 | Leiden University | Master Tax law / Taxation. 
• 1994 - 2007 | Deloitte | Tax Lawyer. 
• 2007 - 2008 | Witlox Van den Boomen | Wage tax specialist. 
• 2008 - 2009 | Fiscount | Wage tax specialist. 
• 2009 - 2024| Mazars | Specialist wage tax / Social security.  
• 2024 - present | Forvis Mazars | Specialist wage tax / Social security.  

Additional positions

• Finally, I regularly give presentations and courses on the above subjects.
• Speaker at internal and external meetings or courses. Are you looking for a speaker on wage tax or social insurance? If so, please contact us by e-mail (university.nl@forvismazars.com) or by phone: +31 (0)88 277 12 34.