Tax Controversy Update February 2023 This Tax Alert addresses certain recent developments concerning procedural tax law in the Netherlands.
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 Member States reach agreement on Pillar Two The Council of the EU announced on 12 December 2022 that the EU Member States had unanimously reached agreement on the directive on the implementation of Pillar Two. It formally adopted the directive three days later.
Webinar 'Tax news for Private Equity and Venture Capital firms' The NVP and Stibbe are organising the webinar 'Tax news for Private Equity and Venture Capital firms' on Tuesday 29 November from 16:00 to 17:15.
Legislative proposal to introduce a temporary solidarity charge for oil and gas companies in 2022 A new legislative proposal was recently announced with the aim of imposing a temporary solidarity charge on companies that (in short) are active in the oil and gas industry.
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.
Dutch Supreme Court answers preliminary questions on redemption of interest rate swaps Recently, the Dutch Supreme Court has answered preliminary questions posed by the District Court of Noord-Nederland regarding the tax treatment of the redemption of interest rate swaps. I
Dutch Spring Memorandum, EU’s DEBRA Proposal and the 2021 Annual Report Advance Tax Rulings rate On Friday 20 May 2022, the Dutch Ministry of Finance published the 2022 Spring Memorandum (Voorjaarsnota), including various proposed amendments that are relevant to international businesses. On 11 May 2022.
Current developments in Dutch tax law This Tax Alert provides an update on three relevant tax development.
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").
The Netherlands launches public consultation on draft bill for Pillar Two implementation On 24 October 2022, the Dutch Government published a draft bill and explanatory notes for public consultation on the implementation of the 15% minimum corporate tax rate following Pillar Two (the “Draft Bill”).
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.
Netherlands Chapter in The Legal 500: Tax Disputes Comparative Guide Reinout de Boer, Michael Molenaars, Rogier van der Struijk and Mieke Lavreysen contributed to The Legal 500: Tax Disputes Comparative Guide in a Q&A chapter about the Netherlands.
Stibbe Tax Seminar "MAPs, Current Corporate Tax Issues and Current Labour & Tax Issues" The Stibbe Tax Seminar "MAPs, Current Corporate Tax Issues and Current Labour & Tax Issues" will take place at our Amsterdam office from 3:00 to 5:00 pm on Thursday 13 October.