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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.

Reinier Kooiman

Senior Associate Amsterdam

Cross-border corporate lending into the Netherlands

Cross-border corporate lending is set for change as CRD VI introduces new licensing obligations, requiring non-EU lenders to reassess their activities in the Netherlands and the EU for all in scope contracts signed on or after 11 July 2026.

Nina Coussement

Senior Associate Brussels

Abolition of Pledge Prohibitions: New Law in Force

The Dutch law on the Abolition of Pledge Prohibitions marks a significant shift in Dutch commercial law, aimed at transforming the landscape for small and medium-sized enterprises to use their receivables as collateral and improve access to financing.

The Netherlands Implements EU Non-Performing Loan Directive

The Dutch Implementation Act on Credit Servicers and Credit Purchasers entered into force on 18 July 2025. It implements EU Directive 2021/2167 regulating NPL sale, purchase and servicing to create a transparent secondary market.

Luxembourg introduces carried interest tax reform

Luxembourg Government’s Draft Bill No. 8590 introduces carried interest tax reforms from 2026, with reduced tax or exemptions, aiming to boost its appeal as a top European fund hub.

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