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Tax Controversy Update February 2023

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

Tax Alert: The European Commission calls on the Netherlands to align taxation of investment funds with EU law

On 25 July 2024, the European Commission initiated an infringement procedure against the Netherlands by sending a letter of formal notice.

Luxembourg Tax Measures 2025

On 11 December 2024, the Luxembourg Parliament approved bills introducing major tax reforms to support businesses and individuals and providing long-awaited clarifications.

Stibbe advises Palex Medical

Stibbe is advising Palex Medical, a Spain-based company specialising in high value-added MedTech equipment and solutions, on its planned acquisition of Duomed, a fast-growing European MedTech distributor.

Stibbe assists Schoolkracht

Stibbe assisted Schoolkracht, a private consortium consisting of AG Real Estate, EPICO², Rebel and Ethias, with the realisation of a DBFM (Design, Build, Finance, Maintain) programme for the first cluster of 27 Schools of Flanders.

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.

The Netherlands' Budget Day 2023

On Tuesday 19 September 2023 (Budget Day; Prinsjesdag) the Dutch Ministry of Finance published the 2024 Tax Package (Pakket Belastingplan) including the 2024 Tax Plan (Belastingplan).

Private Equity in the Netherlands: a Tax Update

In today’s rapidly changing tax environment, it is important to keep an overview of all relevant tax developments.

Luxembourg tax authorities clarify the "CIV carve-out" under the reverse hybrid rules

On 12 August 2025, the Luxembourg tax authorities issued Circular L.I.R. nº 168quater/2, clarifying the interpretation of the Collective Investment Vehicle carve-out from reverse hybrid rules under Art. 168quater(2) of the Luxembourg Income Tax Law.

New double tax treaty concluded with the United Kingdom ratified by Luxembourg

The new double tax treaty between Luxembourg and the United Kingdom (“DTT”) ratified by the Luxembourg Parliament on 19 July 2023 should apply as from 2024.

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.

CBAM: de verplichtingen die nu en straks gelden voor importeurs van bepaalde koolstof-intensieve goederen

Per 1 oktober 2023 is het Carbon Border Adjustment Mechanism (CBAM) in werking getreden. Importeurs van bepaalde koolstof-intensieve goederen moeten rapporteren over de emissies die vrijkomen bij de productie van die goederen.

Findings published from study into Dutch lucrative interest scheme – carried interest / sweet equity

The Dutch Government published findings from a study performed into the Dutch lucrative interest scheme, which scheme generally applies to carried interest / sweet equity arrangements of managers of private equity funds and their portfolio companies.

The Netherlands’ Budget Day 2025

On Tuesday 16 September 2025 (Prinsjesdag), the Dutch Ministry of Finance published the 2026 Tax Plan Package. This consists of the 2026 Tax Plan and Other Tax Measures for 2026, as well as certain additional measures.

Recent developments regarding Foreign Subsidies Regulation, Pillar Two and redemption of interest rate swaps

In this Tax Alert we briefly discuss three recent tax developments.

Proposed amendments in the Dutch 2024 Tax Package related to ESG

On Budget Day the Dutch Ministry of Finance published the 2024 Tax Package, including the 2024 Tax Plan. Certain proposals related to ESG that may be relevant to international businesses are addressed in this Tax Alert.

BEFIT and TP Directive

On 12 September 2023, the European Commission published a proposal for a Council Directive on Business in Europe: Framework for Income Taxation (BEFIT Directive).

Antiabuse Rules: Changes for Holding Companies Investing in the Netherlands

In this issue of Tax Notes International, Ashley Peeters and Michael Molenaars examine two recent Dutch Supreme Court rulings providing more details about antiabuse tests for foreign holding companies that invest in the Netherlands.

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