European Union Adopts Black List of 17 jurisdictions
On 5 December 2017, European Union (EU) finance ministers adopted a list of “non-cooperative jurisdictions for tax purposes” also known as ‘The Black List’. The list is part of the EU's work to counter worldwide tax evasion and avoidance. According to the EU, it will...
Dutch Fiscal Unity Emergency Remedial Measures
On October 25 2017 the Advocate General (“AG”) at the Court of Justice of the European Union (CJEU) published his opinion on the preliminary ruling request of the Dutch Supreme Court in two corporate income tax cases concerning the applicability of the so-called...
Amendment Of Rebuttal Scheme Included In Anti Base-Erosion Rules
The anti-base erosion rule (art.10a CIT) denies deduction of interest on debt, directly or indirectly, owed to related entities or related individuals, if such debt is legally or de facto, directly or indirectly, connected with a 'tainted' transaction (such as certain...
Changes To Dutch Dividend Withholding Tax in 2018
On 19 September 2017, the Dutch government announced several bills containing tax law proposals. Under the legislative proposal (the “Proposal”) changes to the Dutch dividend tax act and the substantial interest taxation rules have been announced. This Tax Update will...
Changes Dutch Dividend Withholding Tax Announced
On 20 September 2016, The Dutch Ministry of Finance (“ the MF”) announced to be working on a new tax act (ultimately entering into force per 1 January 2018) which will have impact on the Dutch dividend withholding tax legislation. In general Dutch public and private...
Ecofin Reaches An Agreement On The ATAD
On 20 June 2016 the EU’s Economic and Financial Affairs Council (“ECOFIN”) agreed on a draft Anti-Tax Avoidance Directive (“ATAD”). Rules in five different fields have been laid down: a) interest limitation rules; b) exit taxation rules; c) general anti-abuse rule...
Dutch Supreme Court Eases Accountability Of Limited Partner In Case Of Violating Management Restrictions
The Dutch Supreme Court overturned a verdict by the Dutch High Court in which it limits the accountability of the limited partner (“Commanditaire Vennoot”) of a partnership (“Commanditaire Vennootschap”) in case the limited partner violates the management...
OECD Releases Revised Discussion Draft On Permanent Establishments
The initial Action 7 discussion draft on PE’s has been replaced by a revised discussion draft, which largely focusses on expanding the scope of the dependent agent rule and narrowing the scope of the “specific activity” PE exemptions as mentioned under the current...
Proposal For UBO Register Adopted By Parliament
On 20 May 2015, the European Parliament adopted the Fourth Money Laundering Directive. This directive obligates EU member states to adopt a UBO-register of corporate and legal entities. Such register should include at least the name, the month and year of birth, the...
KC Legal Nominated In The Category ‘Best Newcomer’ By International Tax Review
International Tax Review, a recognised premium tax news and analysis website, has nominated our firm, Kraaijeveld Coppus Legal, in the category of ‘Best Newcomer’ in the field of tax advisory services.