Corporate Income Tax News

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.
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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.
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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.
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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.
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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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Tax measures in the general coalition agreement

On May 15, 2024 the four coalition parties PVV, VVD, NSC and BBB published their general agreement ‘Hope, Courage and Pride’. The general agreement and the budgetary appendix provide insight into the ...
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Deputy Minister provides more insight into his future tax plans

On April 16, 2024 the Deputy Minister of Finance provided general insights into the upcoming 2025 Tax Plan package in the Tax Policy and Implementation Agenda.
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Dutch Supreme Court renders another judgment on Section 10a and fraus legis

When purely tax-driven and artificial attempts are made to stay (just) outside the formal requirements of Section 10a CITA 1969, the interest deduction can be refused by invoking fraus legis.
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Decree on the Comparison of Foreign Legal Forms published for consultation

Although the method of assessment is less clearly defined than in current qualification policy, the legal forms list may offer more practical certainty.
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