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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.

Combating Non-Arm’s-Length Transfer Pricing in the Netherlands

Charlotte Tolman and Michael Molenaars will contribute periodically to Tax Notes International magazine.

Tackling Reverse-Hybrid and Entity Classification Mismatches In the Netherlands

This article, published in Tax Notes International, examines two recent Dutch proposals, which could have an immediate impact on Dutch and non-Dutch corporate taxpayers and existing national or international structures.

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 contributes to Chambers Tax Controversy 2021

Stibbe’s Tax team contributed to the Dutch chapter of the Chambers and Partners Tax Controversy 2021.

Stibbe tax team contributes to Chambers Global Practice Guides Corporate Tax 2021

A tax team of Stibbe has contributed the Dutch chapter of Chambers Global Practice Guides Corporate Tax 2021.

 

Proposed Amendments to the Dutch Tax Treatment of Stock Option Plans

Recent efforts by the Dutch government to amend the tax treatment of stock option plans are examined by Charlotte Tolman and Michael Molenaars in this article in Tax Notes International.

Netherlands Chapter in The Corporate Tax 2022 guide

Michael Molenaars, Jeroen Smits, Reinout de Boer and Rogier van der Struijk contributed to The Corporate Tax 2022 guide in a chapter about the Netherlands.

Netherlands Chapter in The Tax Disputes and Litigation Review, edition 10

Reinout de Boer, Michael Molenaars, Rogier van der Struijk, Mieke Lavreysen and Tirza Cramwinckel contributed to the Tax Disputes and Litigation review in a chapter about the Netherlands.

Netherlands considers an exit levy proposal in response to corporate relocations

Charlotte Tolman and Michael Molenaars review Dutch efforts to enact a dividend withholding tax exit levy on corporations relocating from the Netherlands and examine how the most recent amendments affect the exit levy proposal.

Stibbe contributes to Chambers Tax Controversy 2022

Stibbe’s Tax team contributed to the Dutch chapter of the Chambers and Partners Tax Controversy 2022.

Luxembourg tax authorities issue circular providing guidance on the special real estate allowance

On 30 May 2022, the Administration des Contributions Directes published a circular concerning the special real estate allowance. The Circular provides for some guidance on the computation of a special real estate rebate.

Restructuring & Insolvency in the Netherlands - 2022

Daisy Nijkamp contributed to the 16th edition of ICLG – Restructuring & Insolvency.

The Unshell directive and its impact on Dutch holding structures

Charlotte Tolman and Michael Molenaars examine the European Commission's proposed Unshell directive, which targets the misuse of shell companies, and its potential impact on Dutch holding structures.

Tax Controversy Netherlands: Update March 2024

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

Update on Dutch entity classification and anti-base-erosion rules

In this issue of Tax Notes International, Ashley Peeters and Michael Molenaars provide a detailed analysis of recent tax developments in Dutch regulations concerning entity classification and anti-base-erosion rules.

Tips for Navigating the 2024 Dutch Tax Roadmap

In this issue of Tax Notes International, Ashley Peeters and Michael Molenaars explain the key markers of the 2024 Dutch Tax Package and provide an overview of the tax developments expected in 2024/2025 and how these may affect international businesses.

Debt or Equity? That Is Still a Dutch Tax Question

In this issue of Tax Notes International, Ashley Peeters and Michael Molenaars examine a recent tax ruling of the Dutch Supreme Court regarding the qualifications of instruments as debt or equity for Dutch tax purposes.

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