Een voorstel tot herziening van de wet toezicht trustkantoren – pra

Short Reads - During our tax webinar on 15 April we discussed certain tax aspects of so-called hybrid entities. Part of this webinar were below videos which zoom in on (i) hybrid mismatches in relation to the ambiguous definition of ‘acting together’ as included in the Dutch conditional withholding tax on interest and royalty payments and referred to by the imported mismatch rule (ATAD2) (clip 1), and (ii) the proposed reverse hybrid mismatch rule (clip 2). 

Short Reads - On 1 January 2021, the Act on confirmation of private restructuring plans (Wet homologatie onderhands akkoord, also known as the “WHOA”, hereinafter: the “Dutch Scheme”) came into effect. We discussed several aspects of the Dutch Scheme in our previous blogs. In order to come to a successful scheme, it is important to consider tax aspects at an early stage of the restructuring process. This blog highlights the most important Dutch tax aspects of the Dutch Scheme.