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Upper House of Dutch Parliament passes 2025 Tax Plan and other tax bills

December 18, 2024
On December 17, 2024, the Upper House of the Dutch Parliament passed the entire 2025 Tax Plan package. It also passed an amending Act and adopted two motions. We have prepared a summary about thi ...

Year end 2024 tax accounting considerations

December 17, 2024
In our memorandum, we highlight the main (IFRS) tax accounting consequences of the 2025 Tax Plan and the disclosure requirements of Pillar 2 for the 2024 financial statements.

Qualification of investment funds as of January 1, 2025: more clarity as a result of Funds Decree and Knowledge Group position of Dutch tax authorities

December 10, 2024
A change in qualification may have far-reaching consequences for the taxation and compliance obligations of investment funds and their unitholders.

The Netherlands issues new decree on OECD Amount B

December 5, 2024
Amount B concerns the contemplated simplified and streamlined transfer pricing rules for determining the remuneration for baseline marketing and distribution activities.

New tax qualification policy: Decree on the Comparison of Foreign Legal Forms published

November 22, 2024
We provide an overview of the latest state of affairs of the new tax qualification policy for (foreign) legal forms that will take effect as of January 1, 2025.

2025 Tax Plan package passed, with several amendments, by Lower House of Parliament

November 15, 2024
We describe the main changes achieved by the adopted amendments and explain several of the motions.

A year longer the time to restructure to a repurchase fund

November 7, 2024
It is intended to prevent investment funds qualifying as non-transparent (independently taxable) for a short period of time when the new rules take effect on January 1, 2025.

8% interest on corporate income tax due contrary to principle of proportionality

November 7, 2024
On November 7, 2024 the Noord-Nederland District Court rendered judgment in a case Meijburg & Co had initiated concerning the interest on tax due charged on a corporate income tax assessment for t ...

Scheme for participations falling below the 5% threshold also applies to covered call options

October 25, 2024
It is noteworthy but unfortunate that the Supreme Court skillfully avoided answering the principal question of whether a split interest in itself constitutes a participation.

Court of Justice of the European Union rules on Section 10a CITA 1969 and EU law

October 8, 2024
In essence, the Court of Justice ruled that the anti-profit shifting provision of Section 10a CITA 1969 is not contrary to the freedom of establishment.

2025 Tax Plan package revised with Memorandums of Amendment

October 4, 2024
The changes to the bill on the Business Succession Tax Relief (Amendment) Act 2025 will especially have a significant practical impact.

Tax measures for 2025

September 17, 2024
The main features of the proposed measures are addressed in our memorandum. We have also prepared a two-page overview of the measures.

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