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...
On 12 June 2014, five Decrees were published by the Dutch Underminister of Finance replacing the current 2004 Decrees on Advance Pricing Agreements (“APA”), Advance Tax Rulings (“ATR”) and “Substance Requirements”. Although the Decrees have affect as per 13 June 2014,...
The Supreme Court rules in two landmark case on the qualification shares having certain features of debt instruments for the Dutch participation exemption. The Supreme Court ruled that shares in Dutch or foreign companies cannot be regarded as debt for Dutch tax law...
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...
A new Decree was adopted introducing substance requirements for all Dutch resident companies which qualify as a financing and/or licensing company. Failing these substance requirements may under specific circumstances result in an administrative penalty up to an...