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Pillar 2 Developments

December 22, 2022
On December 20, 2022 the OECD released three components of the Pillar 2 Implementation Framework. Our KPMG Pillar 2 specialists have prepared a summary of the content of these documents.

Upper House adopts 2023 Tax Plan package and other tax bills

December 21, 2022
On December 20, 2022 the Upper House of Parliament adopted the 2023 Tax Plan package, various other tax bills and seven tax motions. We have prepared a summary about this.

Update: AIFMD reporting requirements for Alternative Investment Fund Managers and non-EU Fund Managers

December 20, 2022
As of Q1 2023 Alternative Investment Fund Managers (AIFMs) and non-EU fund managers who have notified Alternative Investment Funds (AIFs) for marketing in accordance with Articles 36 and 42 of the Alt ...

Termination of banking relationship

December 20, 2022
On August 22, 2022 the District Court of Amsterdam rendered judgment in a case concerning the termination of the banking relationship .The Court ruled that the termination by the bank of the banking r ...

Real estate fiscal investment institution to be abolished and changes to regimes for exempt investment institutions and mutual funds

December 15, 2022
The new rules primarily affect institutional investors, (listed) real estate funds and high-net-worth families.

EU reaches agreement on Pillar 2

December 13, 2022
This is a significant development as the EU is considered a first mover. Other countries are now likely to follow.

Legal qualification of floating solar parks

November 28, 2022
The District Court of Overijssel recently rendered a judgment in respect of a dispute between an owner of a floating solar park (the plaintiff) and the tax officer of the joint tax office Lococensus-T ...

CJEU annuls Commission decision on Luxembourg transfer pricing ruling

November 14, 2022
The decision of the Court of Justice of the European Union brings key clarifications with regard to the choice of a reference system in transfer pricing State aid reviews.

Temporary solidarity contribution by fossil fuel sector

November 3, 2022
A limited number of companies whose activities involve the extraction or refining of oil and gas (approximately 40) are expected to become subject to the solidarity levy.

Policy statement on Hybrid Mismatches updated; no longer double taxation in cost-plus situations

November 3, 2022
The spirit and intent of the anti-abuse measures is thus respected.

Internet consultation on legislative proposal to implement Pillar 2 in the Netherlands

October 25, 2022
The legislative proposal aligns with the proposed EU Directive; in this respect, it is largely similar to the OECD Global Anti-Base Erosion (‘GloBE’) Model Rules.

The 2023 Tax Plan on two pages

September 20, 2022
We have prepared a two-page overview of the measures contained in the 2023 Tax Plan package.

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