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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).

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 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).

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.

The Netherlands' Budget Day 2020: the impact of the Dutch 2021 Tax Package on international businesses

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

Tax Alert: The Netherlands' Budget Day 2019: the impact of the Dutch 2020 Tax Package on international businesses

On Tuesday 17 September 2019 (Prinsjesdag) the Dutch Ministry of Finance published the 2020 Tax Package (Belastingpakket) including the 2020 Tax Plan (Belastingplan), i.e. a set of legislative proposals amending the national tax laws for the upcoming year

Revised policy concerning (1) fixed establishments in VAT groups and (2) transfer pricing

On 5 July 2022, the Dutch State Secretary of Finance published an amendment to the decree on the Dutch value added tax ("VAT") treatment of fixed establishments (the "Decree").

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.

COVID-19 update and Guidelines published on the Dutch implementation of DAC6

The EU Mandatory Disclosure Directive (“DAC6”), introducing a reporting requirement for intermediaries and/or taxpayers of certain cross-border arrangements that are perceived to be aggressive, is effective as of 1 July in the Netherlands. By his letter o

Recent developments regarding (1) the tax treatment of W&I premiums and payouts; (2) the Dutch Supreme Court’s prejudicial questions following the CJEU Lexel ruling; and (3) the consultation on the modernization of Dutch partnerships

On 18 October 2022, the Dutch State Secretary of Finance published a document regarding certain Dutch corporate income tax considerations in respect of premiums and payouts under a Warranties and Indemnities (W&I) insurance.

Dutch Supreme Court: property rights also require a leveraged effect of more than 1 in 10 to qualify as lucrative interest

The Dutch Supreme Court issued an interesting court decision on 14 April 2023 clarifying when property rights (vermogensrechten) are economically similar or comparable to subordinated classes of shares that constitute a lucrative interest.

Tax Controversy Update February 2023

This Tax Alert addresses certain recent developments concerning procedural tax law in the Netherlands.

CBAM: current and future obligations for importers of certain carbon-intensive goods

The Carbon Border Adjustment Mechanism (CBAM) came into force on 1 October 2023. Importers of certain carbon-intensive goods have to report on emissions released during the production of those goods.

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