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.
In practice, large amounts in dividend tax are avoided via various forms of dividend stripping, which the Dutch tax authorities cannot properly combat with the legal instruments currently available to ...
In particular, the Supreme Court answered several outstanding questions about Section 10a Corporate Income Tax Act 1969, such as when is there an ‘intra-group (non-business motivated) diversion’.
The most important changes are the incorporation of the results of the OECD’s BEPS project and the source exemption that was introduced into the Corporate Income Tax Act 1969 in 2012.
The changes to the Decree are mainly a reaction to the changes made to the OECD guidelines in respect of financial transactions, intra-group services and recent OECD publications on the treatment of g ...
The new Dutch Transfer Pricing Decree was published on July 1, 2022. The new decree focuses on recent developments that have resulted in changes to the OECD Transfer Pricing Guidelines but also ...
The planned tax measures include a reduction in the step-up corporate income tax bracket, the introduction of two tax brackets in Box 2, a cap on the 30% ruling and an increase in the general real est ...
The CJEU provided more guidance on the circumstances in which the human and technical resources of an independent legal entity could result in a separate fixed establishment.
The bill introduces a reporting obligation for digital platform operators to provide the Dutch tax authorities with information about certain users (‘sellers’) on their platform.
