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.
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.
Uiteindelijk is het aan de Hoge Raad om te beslissen of met de Wet rechtsherstel box 3 voldoende rechtsherstel wordt geboden. Advocaat-generaal Wattel meent in ieder geval van niet.
The memorandum in response to the report provides answers to many questions, but there are still many points that need further elaboration, especially at the OECD level.
The new treaty will apply at the earliest from January 1, 2024 (but probably only from January 1, 2025). We have summarized some important aspects of the new treaty.
The Netherlands is thus the first EU Member State to have submitted a bill to transpose EU Directive 2022/253 of December 14, 2022 into national legislation.
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.
