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...
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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...
EU And Switzerland Initiate Tax Transparency
The European Union and Switzerland have initiated an agreement that will require both Switzerland and the EU member states to automatically exchange information as of 2018 in relation with the financial accounts of their...
Underminister Of Finance Informs Parliament On Ruling Practice
In an effort to provide as much transparency on the Dutch Ruling practice as possible without violating confidentiality, the Dutch Under Minister of Finance provided insight information on the Dutch ruling practice in a letter to...
EU Court of Justice Ruled Dutch Fiscal Unity Regime In Contravention
On the 12 June 2014, the European Court of Justice ruled that the Dutch fiscal unity regime (treating multiple group companies as one single taxpayer), contravenes to the EU principle of Freedom of Establishment. In essence the infringement was caused as the Dutch...
New Tax Arrangement For The Netherlands And Curacao
On 10 June 2014, the proposed new bilateral arrangement for the avoidance of double taxation for the Netherlands and Curacao (the “TNC”) was presented to Dutch Parliament. The TNC shall replace the current Tax Arrangement of the Kingdom and is expected to enter into...
Netherlands And Curaçao Reach Agreement On New Bilateral Tax Arrangement
On December 12, the Dutch Ministry of Finance announced that Curaçao and The Netherlands have reached agreement on the text of a new bilateral arrangement for the avoidance of double taxation (the “Arrangement”). The Arrangement shall replace the current Tax...