100 results Key markers on the Dutch Tax roadmap for 2023 In the latest installment of Tax Notes International, Charlotte Tolman and Michael Molenaars discuss major Dutch tax plans and developments expected for 2023 and how they may affect international business. EU Member States reach agreement on Pillar Two The Council of the EU announced on 12 December 2022 that the EU Member States had unanimously reached agreement on the directive on the implementation of Pillar Two. It formally adopted the directive three days later. Pillar Two – a new reality for the tax position of MNEs As of 1 January 2024, large-scale domestic and multinational groups within in the EU will face a minimum effective tax rate of 15%, as a result of the agreement reached by the EU Member States on the Directive implementing Pillar Two (the Directive). Dutch Supreme Court rules that refurbishment of former woolen fabrics factory into retail center resulted in 'essentially new constructed real estate' for VAT purposes On Friday 11 November 2022 the Dutch Supreme Court ruled that the refurbishment of a former woolen fabrics factory into a retail centre resulted in ‘essentially new constructed real estate’ (in wezen nieuwbouw) for Dutch VAT purposes. Proposal for a Directive to prevent misuse of shell entities (ATAD 3) and the amendments proposed by the European Parliament In mid-January 2023, the European Parliament approved the European Commission’s draft directive to prevent misuse of shell entities for tax purposes (known as ATAD 3), as amended by its Committee on Economic and Monetary Affairs. 2023 Spring Memorandum includes several policy proposals for tax measures relevant for the Dutch real estate market The Dutch government published the annual Spring Memorandum on Friday 28 April 2023. In this blog post, the policy proposals for tax measures included in the Spring Memorandum that are relevant for real estate investments in the Netherlands are discussed. Stibbe Brussels appoints five new Counsel Stibbe Brussels has promoted Bastiaan Schelstraete (Environment & Planning), Stefanie François (Environment & Planning), David Verwaerde (Dispute Resolution), Lizelotte De Maeyer (Tax) and Pieter-Jan Leemen (Banking & Finance) to Counsel. EU Commission presents proposals for directives against shell entities and ensuring a global minimum level of taxation On 22 December 2021 the European Commission (hereinafter: ‘EC’) presented two legislative proposals for EU directives, one to introduce a global minimum corporate tax rate and one to target EU shell entities. The key aspects of both proposals are discusse The New Dutch Conditional Withholding Tax And Hybrid Entities Charlotte Tolman and Michael Molenaars explain the Netherlands’ conditional withholding tax regime, which applies to interest and royalty payments to low-tax jurisdictions and aims to curtail profit shifting, and its implications for hybrid entities. The Dutch Scheme – tax aspects 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. Tax Controversy: Update July 2021 This Alert addresses certain recent developments concerning procedural tax law in the Netherlands. We will discuss some interesting developments with regard to the (revised) Dutch tax ruling practice as per 1 July 2019 and the Tax Ruling Annual Report. Stibbe Tax Webinar on Dutch classification rules – update on Dutch FGR’s On 1 July 2021, the Dutch state secretary of Finance issued a letter in which he indicated that the proposed amendments to the Dutch fund for joint account will no longer be part of the legislative proposal on the Dutch classification rules. The response of the Dutch government to the G7 Tax initiative On 14 June 2021 the Dutch State Secretary of Finance sent a letter to the Dutch Parliament setting out his view on (i) the political agreement reached by the G7 countries on global tax reform and (ii) the next meeting of the OECD/G20 Inclusive Framework. Stibbe Tax webinar on Hybrid Entities During our tax webinar on 15 April we discussed certain tax aspects of so-called hybrid entities. Public consultation on proposed amendment of Dutch classification rules for certain domestic and foreign legal entities On 29 March 2021 the Dutch government has released a consultation document (the “Consultation Document”) containing a draft bill of law and explanatory memorandum to amend the Dutch classification rules for certain domestic and foreign legal entities. Dutch conditional withholding tax on dividends A legislative proposal regarding a conditional withholding tax on dividends (if adopted: effective as of 1 January 2024) (Wetsvoorstel bronbelasting dividenden) was submitted to Dutch parliament on Thursday 25 March 2021. Consultation on ATAD 2 (reverse hybrids) and amendment arm’s-length principle in the Netherlands As noted in our earlier Tax Alerts of March 2017 and July 2019, the EU Anti-Tax Avoidance Directive 2 ("ATAD 2") provides for minimum standards to neutralize hybrid mismatches and came into effect in the Netherlands as of 1 January 2020. The Netherlands' Budget Day 2021: the impact of the Dutch 2022 Tax Package on international businesses On Tuesday 21 September 2021 (Budget Day; Prinsjesdag) the Dutch Ministry of Finance published the 2022 Tax Package (Belastingpakket) including the 2022 Tax Plan (Belastingplan). Pagination Current page 1 Page 2 Page 3 Page 4 Next page
Key markers on the Dutch Tax roadmap for 2023 In the latest installment of Tax Notes International, Charlotte Tolman and Michael Molenaars discuss major Dutch tax plans and developments expected for 2023 and how they may affect international business.
EU Member States reach agreement on Pillar Two The Council of the EU announced on 12 December 2022 that the EU Member States had unanimously reached agreement on the directive on the implementation of Pillar Two. It formally adopted the directive three days later.
Pillar Two – a new reality for the tax position of MNEs As of 1 January 2024, large-scale domestic and multinational groups within in the EU will face a minimum effective tax rate of 15%, as a result of the agreement reached by the EU Member States on the Directive implementing Pillar Two (the Directive).
Dutch Supreme Court rules that refurbishment of former woolen fabrics factory into retail center resulted in 'essentially new constructed real estate' for VAT purposes On Friday 11 November 2022 the Dutch Supreme Court ruled that the refurbishment of a former woolen fabrics factory into a retail centre resulted in ‘essentially new constructed real estate’ (in wezen nieuwbouw) for Dutch VAT purposes.
Proposal for a Directive to prevent misuse of shell entities (ATAD 3) and the amendments proposed by the European Parliament In mid-January 2023, the European Parliament approved the European Commission’s draft directive to prevent misuse of shell entities for tax purposes (known as ATAD 3), as amended by its Committee on Economic and Monetary Affairs.
2023 Spring Memorandum includes several policy proposals for tax measures relevant for the Dutch real estate market The Dutch government published the annual Spring Memorandum on Friday 28 April 2023. In this blog post, the policy proposals for tax measures included in the Spring Memorandum that are relevant for real estate investments in the Netherlands are discussed.
Stibbe Brussels appoints five new Counsel Stibbe Brussels has promoted Bastiaan Schelstraete (Environment & Planning), Stefanie François (Environment & Planning), David Verwaerde (Dispute Resolution), Lizelotte De Maeyer (Tax) and Pieter-Jan Leemen (Banking & Finance) to Counsel.
EU Commission presents proposals for directives against shell entities and ensuring a global minimum level of taxation On 22 December 2021 the European Commission (hereinafter: ‘EC’) presented two legislative proposals for EU directives, one to introduce a global minimum corporate tax rate and one to target EU shell entities. The key aspects of both proposals are discusse
The New Dutch Conditional Withholding Tax And Hybrid Entities Charlotte Tolman and Michael Molenaars explain the Netherlands’ conditional withholding tax regime, which applies to interest and royalty payments to low-tax jurisdictions and aims to curtail profit shifting, and its implications for hybrid entities.
The Dutch Scheme – tax aspects 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.
Tax Controversy: Update July 2021 This Alert addresses certain recent developments concerning procedural tax law in the Netherlands. We will discuss some interesting developments with regard to the (revised) Dutch tax ruling practice as per 1 July 2019 and the Tax Ruling Annual Report.
Stibbe Tax Webinar on Dutch classification rules – update on Dutch FGR’s On 1 July 2021, the Dutch state secretary of Finance issued a letter in which he indicated that the proposed amendments to the Dutch fund for joint account will no longer be part of the legislative proposal on the Dutch classification rules.
The response of the Dutch government to the G7 Tax initiative On 14 June 2021 the Dutch State Secretary of Finance sent a letter to the Dutch Parliament setting out his view on (i) the political agreement reached by the G7 countries on global tax reform and (ii) the next meeting of the OECD/G20 Inclusive Framework.
Stibbe Tax webinar on Hybrid Entities During our tax webinar on 15 April we discussed certain tax aspects of so-called hybrid entities.
Public consultation on proposed amendment of Dutch classification rules for certain domestic and foreign legal entities On 29 March 2021 the Dutch government has released a consultation document (the “Consultation Document”) containing a draft bill of law and explanatory memorandum to amend the Dutch classification rules for certain domestic and foreign legal entities.
Dutch conditional withholding tax on dividends A legislative proposal regarding a conditional withholding tax on dividends (if adopted: effective as of 1 January 2024) (Wetsvoorstel bronbelasting dividenden) was submitted to Dutch parliament on Thursday 25 March 2021.
Consultation on ATAD 2 (reverse hybrids) and amendment arm’s-length principle in the Netherlands As noted in our earlier Tax Alerts of March 2017 and July 2019, the EU Anti-Tax Avoidance Directive 2 ("ATAD 2") provides for minimum standards to neutralize hybrid mismatches and came into effect in the Netherlands as of 1 January 2020.
The Netherlands' Budget Day 2021: the impact of the Dutch 2022 Tax Package on international businesses On Tuesday 21 September 2021 (Budget Day; Prinsjesdag) the Dutch Ministry of Finance published the 2022 Tax Package (Belastingpakket) including the 2022 Tax Plan (Belastingplan).