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Perpetual securities not considered equity for Dutch corporate income tax purposes

In a decision of Friday 15 May 2020, the Dutch Supreme Court confirmed that fixed-to-floating rate perpetual equity securities (“perpetual securities”) should not be considered a “participation loan” (deelnemerschapslening) for Dutch tax purposes. Under D

Stibbe advises Tata Communications on the acquisition of Teleena

Stibbe advises Tata Communications, a leading global digital infrastructure provider, on the acquisition of Teleena, a Netherlands-based Internet of Things (IoT) connectivity specialist and mobile virtual network enabler (MVNE).

Tax Alert: Public consultation additional source taxation on dividends to low tax jurisdictions

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

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: Dutch implementation of the EU Directive on Tax Dispute Resolution

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

Tax Alert: Legislative proposal on Dutch implementation of ATAD 2 (anti-hybrid rules)

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

Consultation Document new Dutch Tax group regime released

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.

Tax Alert: Consultation Document new Dutch Tax group regime released

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

Initial guidance from the Dutch State Secretary of Finance on the "Danish Cases" relating to beneficial ownership

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

Transitional rules announced for certain Dutch tax acts in case of no deal Brexit

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

Tax Alert: Adoption 2019 Tax Plan and ATAD 1 proposal by the Dutch Lower House of Parliament

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

Tax Alert: No abolition of Dutch dividend withholding tax

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

CJEU decision on a refund of Dutch dividend withholding tax for foreign investment funds

Dutch dividend withholding tax has been a hot topic the last few years. In 2018 there were discussions on whether the Dutch dividend withholding tax should be abolished or not. One of the arguments to abolish related to the potential risk of the Dutch div

Dutch international taxation - current developments

The global debate on alleged aggressive international tax planning initiated by the G20/OECD and the EU, is an important driver of the current developments in the field of international taxation. The following is a high level summary of certain developmen

Further guidance on Dutch ATAD implementation and measures against letterbox companies

Further to the policy plans published by the Dutch government in October 2017, the Dutch State Secretary of Finance published on February 23, 2018 a Letter (the "Letter") containing further details on certain aspects of the Dutch government's two way appr

ECJ ruling on Dutch CIT Fiscal Unity prompts legislative action

In this Tax Alert we will address the anxiously awaited ruling of the European Court of Justice ("ECJ") on the joined cases C-398/16 and C-399/16. This judgement deals with the question whether EU law obliges the Netherlands to let taxpayers cherry pick b

Abolishment of tax deductibility of coupon payments on AT-1 capital instruments announced per 1 January 2019

On Friday 29 June 2018, the Dutch government made public its intention to abolish article 29a Dutch corporate income tax act ('DCITA'), per 1 January 2019. As a result of the abolishment of this provision, coupon payments on so-called additional-tier 1 ('

Tax Alert: Budget Day tax proposals

On 18 September it was budget day (Prinsjesdag) in the Netherlands on which the Dutch government released several bills of law containing tax law proposals. In this Tax Alert we will provide you with a summary of the main proposals relevant for internatio

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