Corporate Income Tax News

New tax qualification policy: Decree on the Comparison of Foreign Legal Forms published

We provide an overview of the latest state of affairs of the new tax qualification policy for (foreign) legal forms that will take effect as of January 1, 2025.

2025 Tax Plan package passed, with several amendments, by Lower House of Parliament

We describe the main changes achieved by the adopted amendments and explain several of the motions.

8% interest on corporate income tax due contrary to principle of proportionality

On November 7, 2024 the Noord-Nederland District Court rendered judgment in a case Meijburg & Co had initiated concerning the interest on tax due charged on a corporate income tax assessment for t ...

A year longer the time to restructure to a repurchase fund

It is intended to prevent investment funds qualifying as non-transparent (independently taxable) for a short period of time when the new rules take effect on January 1, 2025.

Scheme for participations falling below the 5% threshold also applies to covered call options

It is noteworthy but unfortunate that the Supreme Court skillfully avoided answering the principal question of whether a split interest in itself constitutes a participation.

Court of Justice of the European Union rules on Section 10a CITA 1969 and EU law

In essence, the Court of Justice ruled that the anti-profit shifting provision of Section 10a CITA 1969 is not contrary to the freedom of establishment.

2025 Tax Plan package revised with Memorandums of Amendment

The changes to the bill on the Business Succession Tax Relief (Amendment) Act 2025 will especially have a significant practical impact.

Tax measures for 2025

The main features of the proposed measures are addressed in our memorandum. We have also prepared a two-page overview of the measures.

Important judgment on tax classification of financial instrument

On May 17, 2024 the Dutch Supreme Court rendered an important judgment on the tax qualification of a financial instrument that was issued by a company established in France in 2007. It concerned the ‘ ...

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