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SearchSearch results for: “january-anma.icu”

92 results

Bill of law on interest and royalties paid to non-cooperative jurisdictions

The Luxembourg Government proposes to introduce the non-deductibility of interest and royalties expenses of a Luxembourg taxpayer towards collective entities located in a blacklisted jurisdiction.

Luxembourg tax measures on non-cooperative jurisdictions: EU blacklist updated

The European Union updates non-cooperative jurisdictions list, affecting bill of law nº 7547. From Jan 1, 2021, interest or royalties paid to related enterprises in listed countries won't be tax-deductible.

Tax Alert – Update Letter published on issues and solutions regarding the new definition of the FGR

On 12 June 2025, the Dutch State Secretary of Finance published an update letter addressing certain identified issues and potential solutions in connection with the new definition of the Dutch fund for joint account (fonds voor gemene rekening, or FGR).

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.

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.

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

Stibbe advises the Walloon Transport Operator

Stibbe assisted the Walloon Transport Operator (OTW) with the creation of a brand new tramway network (11.7 km) including the construction of 21 stations and a new depot and the acquisition of trams in Liège, Wallonia.

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

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