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The Dutch Supreme Court issued two rulings that provide guidance on how to apply the Dutch dividend withholding tax exemption, more specifically the anti-abuse provisions therein.
Continue Reading Dutch Supreme Court Rules on Anti-Abuse in Dividend Withholding Tax Exemptions
On Feb. 19, 2024, the Organization for Economic Cooperation and Development (OECD) amended its transfer pricing guidelines to include “Amount B,” a standardized approach to determine the arm’s length remuneration for certain marketing and distribution activities. The updated guidelines apply for fiscal years beginning on or after Jan. 1, 2025. In December 2024, the OECD
New partnership rules set to take effect in 2025 may subject regulated funds using tax-transparent Dutch Commanditaire Vennootschap (CV) structures to Dutch corporate income tax (CIT) and dividend withholding tax (DWT). The CV is a frequently used partnership vehicle to structure regulated funds and associated feeder/investment entities.
Per 1 January 2023, the Dutch RETT (real estate transfer tax) will increase from 8% to 10.4%. Transactions that close after 31 December 2022 will therefore be subject to a 2.4% higher transfer tax.
It may be possible to avoid this by applying a Provisional Closing Scheme (Groninger akte structuur). This essentially means that the
As of 1 January 2023, a set of tax changes will be implemented that may affect one’s Dutch tax position. In addition, changes starting in 2024 have also been announced. This blog post provides an overview of the most important changes, with special attention to real-estate-related activities.
The Dutch corporate
Tracking the financial covenants in loan documents is a key priority for borrowers in a bear market.
Breach of a financial covenant ultimately may lead to acceleration of the outstanding loan(s). The more likely scenario, however, at least in the short term, is a cash trap (when rent income, which would otherwise have been available
On Budget Day, 20 September 2022 (Prinsjesdag), the Dutch Ministry of Finance presented its 2023 tax plan (the Proposal). For the proposed bills discussed in this GT Alert to have effect, Parliament first must approve them. If approved, many of the proposed measures would take effect 1 January 2023.
On Budget Day, 21 September 2021 (Prinsjesdag), the Dutch Ministry of Finance presented its 2022 tax plan. For the proposed bills in this plan to have effect, they first must be approved by Parliament. If approved later this year, many of the proposed measures will take effect on 1 January 2022. This GT
On March 24, 2021, the Netherlands and Germany signed a protocol to amend the tax treaty between the two states (the Protocol). The tax treaty prevents, on the one hand, double taxation by companies or citizens and, on the other hand, non-taxation. The Protocol contains agreements on the right to levy taxes on (short-term)
On 16 November 2020, the Dutch government published a protocol to amend the “Convention between the Kingdom of the Netherlands and the Republic of Poland for the elimination of double taxation with respect to taxes on income and the prevention of tax evasion and avoidance.” This followed the signing of the Protocol on 29 October