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
The global minimum tax (GMT) tax took effect in more than 40 jurisdictions in 2024. This GT Alert highlights elements to consider before year-end.
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.
The Carbon Border Adjustment Mechanism (CBAM) is the European regulation that imposes a reporting obligation and a carbon tax on EU imports of certain goods in order to reduce carbon emissions. See our prior GT Alert.
The CBAM Regulation officially took effect May 17, 2023. It will apply in phases starting Oct. 1, 2023
The Dutch legislator is considering changing the Dutch RETT (real estate transfer tax) scheme regarding acquisitions of Dutch real estate via share deals. If this change is indeed implemented, then effective 1 January 2024, the current RETT exemption on the acquisition of shares in a real estate entity holding newly developed real estate would cease
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 16 February 2022, the Netherlands and Colombia signed a tax treaty for the elimination of double taxation and the prevention of tax evasion and avoidance. The Treaty prevents double taxation and contributes to the economic interests of both countries.