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On 25 September 2020, the under minister of Finance released a draft legislative proposal open for public consultation until 23 October 2020. The draft legislative proposal includes a source taxation on profit distributions by Dutch companies to sharehold

In this Tax Alert we will summarize three recent tax developments that are relevant for international business with presence in the Netherlands.

Op 25 april 2018 heeft de Europese Commissie een voorstel voor een richtlijn gepubliceerd met betrekking tot grensoverschrijdende omzettingen, fusies en splitsingen.

On 9 July 2019, the Senate approved the bill on tax arbitration which implements the EU Directive on tax dispute resolution mechanisms in the European Union ("EU Directive on Tax Dispute Resolution") into Dutch national legislation. The bill will be publi

On 2 July 2019, the Dutch State Secretary of Finance has published a legislative proposal to implement the EU Anti-Tax Avoidance Directive 2 ("ATAD 2") into Dutch domestic legislation (the "Bill"). ATAD 2 provides for minimum standards to neutralize hybri

Last Friday 28 June 2019, the Decree on the revised international tax ruling practice as issued by the Dutch Ministry of Finance has been published. The Decree has become effective as per today 1 July 2019.

A public consultation document was published by the State Secretary of Finance on 17 June 2019 which includes four alternative concepts for a tax group regime.

On 22 February 2018 the European Court of Justice ("ECJ") ruled that the effective non-application of the Dutch anti-base erosion rules in domestic corporate income tax fiscal unity situations breaches the principle of freedom of establishment (see our ta

On 26 February 2019 the European Court of Justice ("ECJ") ruled in various cases regarding the interpretation and non-application of the Parent-Subsidiary Directive ("PSD") and Interest and Royalties Directive ("IRD") in the context of tax avoidance and b

In the Netherlands, tax controversies can arise in various ways. Tax disputes may arise as a result of a tax audit initiated by the Dutch Tax Authorities (DTA), or questions raised by the DTA (for example, after having reviewed a tax return filed by a tax

On 23 April 2019 the Dutch State Secretary of Finance has published a draft decree (the "Decree") and further guidance on the revised Dutch tax ruling practice for tax rulings with an international character ("international tax rulings"), expected to beco

Rogier Raas and Jeroen Smits have contributed the Dutch Chapter for the International Comparative Legal Guide to Public Investment Funds Laws and Regulations.

Stibbe contributes Dutch chapter to Chambers Global Practice Guides Corporate Tax 2019. This chapter was written by Michael Molenaars, Jeroen Smits, Reinout de Boer and Rogier van der Struijk. Besides providing you with an outline of Dutch corporate incom

On 4 February 2019, the Dutch State Secretary of Finance sent a letter to the Dutch Parliament announcing transitional rules for Dutch taxes (other than customs legislation) if there will not be a Brexit withdrawal agreement (i.e. a no deal Brexit). The l

A Brexit without a deal, or with a deal that does not cover all relevant aspects, is still a potential scenario. We have highlighted a number of unexpected legal consequences of Brexit in such a no deal or incomplete deal scenario.

In his letter of 22 November 2018 (the “Letter”), the Dutch State Secretary of Finance outlines the revised Dutch ruling practice for tax rulings with an international character (“international tax rulings”), aimed to become effective as from 1 July 2019.

Further to the several tax proposals released by the Dutch government on Budget Day last September (the 'Proposals' –  see also our Tax Alerts of 20 September 2018 and 16 October 2018), on 15 November 2018 the Lower House of Parliament has adopted the 201

Further to the several tax proposals released by the Dutch government on Budget Day last month (see our Tax Alert of 20 September 2018), on 15 October the Dutch State Secretary of Finance sent a letter to the Dutch parliament containing a reconsideration