Dutch Supreme Court judgment on the crediting of dividend withholding tax

On January 19, 2024 the Dutch Supreme Court clarified the rules applying to the crediting of dividend withholding tax for corporate income tax purposes.

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2023 Guidelines on Mandatory Disclosure Rules (DAC6) published

May 9, 2023
The updated Guidelines include several substantive changes compared to the earlier version.

Pillar 2 Developments

December 22, 2022
On December 20, 2022 the OECD released three components of the Pillar 2 Implementation Framework. Our KPMG Pillar 2 specialists have prepared a summary of the content of these documents.

New referral to the CJEU – Net taxation – Taxation of dividend income received by a non-resident insurance company

December 14, 2022
On December 14, 2022 the Court of Appeals in ‘s-Hertogenbosch asked the Court of Justice of the EU (CJEU) for a preliminary ruling in a case dealing with net taxation.

EU reaches agreement on Pillar 2

December 13, 2022
This is a significant development as the EU is considered a first mover. Other countries are now likely to follow.

VAT in the Digital Age proposal issued to modernize the EU VAT system

December 9, 2022
The proposal from the European Commission covers three issues: (1) Digital Reporting Requirements (2) the VAT treatment of the platform economy and (3) changes to e-commerce rules and a ‘single VAT re ...

Court of Justice of the European Union rules that the UBO register must not be publicly accessible

November 23, 2022
The Minister of Finance has asked the Dutch Chamber of Commerce to temporarily stop providing information from the UBO register, effective as of November 22, 2022.

Dutch Supreme Court persists with strict interpretation of actual use for VAT recovery right purposes

November 11, 2022
This case is not only relevant for financial institutions, but also for other taxpayers performing VAT-taxed and VAT-exempt services.

Policy statement on Hybrid Mismatches updated; no longer double taxation in cost-plus situations

November 3, 2022
The spirit and intent of the anti-abuse measures is thus respected.

European Commission publishes proposal for a directive to tackle the misuse of shell entities

December 28, 2021
On December 22, 2021 the European Commission published a proposal for a directive aimed at preventing the misuse of shell entities and arrangements for tax purposes.

Report of the Conduit Companies Committee

November 26, 2021
The report contains 15 recommendations, divided into six tax and nine non-tax policy options. At the same time, the Deputy Minister of Finance sent the government’s response to this report to the Lowe ...

CJEU: Member State registration ownership of vessel may levy insurance premium tax

April 19, 2021
This judgment is not only important for the insurance of seagoing vessels, for which an exemption applies in the Netherlands, but also for the insurance of other vessels, which are subject, as startin ...

New policy statement on VAT fixed establishments

January 14, 2021
The policy statement, among other things, lays down the Dutch viewpoint on the concept of a fixed establishment and the VAT treatment of transactions between a head office and a fixed establishment.

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