El 5 de diciembre de 2017, los ministros de Finanzas de la Unión Europea (UE) adoptaron una lista de "jurisdicciones no cooperativas a efectos fiscales", también conocida como "La Lista Negra". La lista forma parte de la labor de la UE contra la evasión y elusión...
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...
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...
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...
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...
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...
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...
The initial Action 7 discussion draft on PE’s has been replaced by a revised discussion draft, which largely focusses on expanding the scope of the dependent agent rule and narrowing the scope of the “specific activity” PE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...
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...