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Perpetual securities not considered equity for Dutch corporate income tax purposes

In a decision of Friday 15 May 2020, the Dutch Supreme Court confirmed that fixed-to-floating rate perpetual equity securities (“perpetual securities”) should not be considered a “participation loan” (deelnemerschapslening) for Dutch tax purposes. Under D

Financial difficulties due to the coronavirus: what about taxes?

In the context of the coronavirus the Belgian tax authorities have issued aid measures concerning taxation with the aim of supporting enterprises and natural persons facing financial difficulties. This short read, provides an overview of these measures.

OECD issues guidance on the impact of the COVID-19 crisis on tax treaties

As noted in our Short Read of 31 March 2020, multiple states have been implementing travel restrictions and mandatory quarantines in an effort to stop the spread of the corona virus (COVID-19). Governments have also taken measures to mitigate the economic

Bill of law on interest and royalties paid to non-cooperative jurisdictions

The Luxembourg Government proposes to introduce the non-deductibility of interest and royalties expenses of a Luxembourg taxpayer towards collective entities located in a blacklisted jurisdiction.

How to meet (Dutch) substance requirements during the COVID-19 pandemic?

Measures taken by multiple jurisdictions in an attempt to stop the spread of the corona virus (COVID-19) affect many people and businesses.

Draft bill of law regarding certain payments to non-cooperative jurisdictions

Luxembourg's Government announces draft bill of law addressing interest/royalties payments to related entities established in a country or territory listed under the EU list of non-cooperative jurisdictions for tax purposes.

DAC 6 introduced under Luxembourg law

On 21 March 2020, the Luxembourg Parliament voted to approve the law implementing the Council Directive (EU) 2018/822 which introduces disclosure obligations for intermediaries and taxpayers of certain reportable cross-border arrangements (the “Law”).

Additional Dutch tax measures to provide relief for economic impact corona crisis

Further to the measures already announced on 12 March 2020, the Dutch government earlier this week announced additional extraordinary measures (both tax and non-tax related) to mitigate the economic impact of the corona crisis. Below we will summarize som

Luxembourg tax measures on non-cooperative jurisdictions: EU blacklist updated

The European Union updates non-cooperative jurisdictions list, affecting bill of law nº 7547. From Jan 1, 2021, interest or royalties paid to related enterprises in listed countries won't be tax-deductible.

Dutch Supreme Court: non-resident investment fund eligible for refund of Dutch dividend withholding tax

On 23 October 2020, the Dutch Supreme Court ruled that a non-resident UCITS fund is eligible for a refund of Dutch dividend withholding tax with respect to its investments in the Netherlands if strict criteria are met.

Johan Léonard and Roberto de Castro Mendonça write on taxation of crypto assets

Stibbe Luxembourg's tax lawyers Johan Léonard and Roberto de Castro Mendonça authored the Luxembourg chapter of the multi-jurisdictional book titled "Taxation of Crypto Assets".

Chambers and Partners Real Estate Global Practice Guide 2020 - Luxembourg chapter

Claire-Marie Darnand, Victorien Hémery, Johan Léonard, Tom Storck, Benjamin Marthoz, Audrey Jarreton and François Bernard have all contributed to the 2020 Chambers and Partners Real Estate Global Practice Guide, providing the Luxembourg chapter. 

Report of advisory committee on taxation of multinationals in the Netherlands

The Dutch Lower House of Parliament adopted a motion that called on the Government to initiate and set up a committee of experts to explore fair multinational profit taxation. A report was submitted to Parliament last Wednesday (15 April 2020).

Real estate and the impact of COVID-19

COVID-19 is increasingly disrupting our real estate industry. This article provides you with answers to some of the legal questions raised by the real estate industry during this crisis.

Dutch Tax Aspects of Debt Restructurings

In this issue of Tax Notes International, Ashley Peeters and Michael Molenaars analyse key tax considerations related to restructurings in the Netherlands.

Chambers Tax Controversy 2025

Reinout de Boer, Michael Molenaars, Rogier van der Struijk and Linde Respen contributed to Chambers Tax Controversy 2025 in a chapter about Tax Law and Practice in the Netherlands.

Tax Alert - Update regarding the Dutch lucrative interest scheme, measures tackling dividend stripping and fragmenting of real estate companies

The Dutch Ministry of Finance has recently published letters on three important tax-related issues. This Tax Alert discusses the proposed changes and their potential impact on international companies.

Netherlands Chapter in The International Comparative Legal Guide

Jeroen Smits and Rogier Raas contributed to the International Comparative Legal Guide - Public Investment Funds 2023 in a Q&A chapter about the Netherlands.

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