Dividend witholding tax

Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting signed by the Netherlands and other countries

On June 7, 2017, the Dutch Minister of Finance Dijsselbloem and other high-level representatives of 67 countries representing 68 jurisdictions signed the Multilateral Convention (“Multilater ...
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Internet consultation on tax treaty policy and designation of low-taxed states

On September 25, 2018 the government launched an internet consultation, giving interested parties the opportunity to raise issues that are important to them relating to i) Dutch tax treaty policy and ...
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Bill on the Fiscal Unity Emergency Repair Act adopted by the Lower House

On February 12, 2019, the bill on the Fiscal Unity Emergency Repair Act (Wet spoedreparatie fiscale eenheid) was adopted by the Lower House. This bill was explained in our previous memoranda dated&nbs ...
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Dutch Lower House of Parliament passes Bill on ratification of the MLI

On February 12, 2019 the Dutch Lower House of Parliament passed the Bill for the ratification of the Multilateral Convention (“MLI”) to Implement Tax Treaty-Related Measures to Prevent Base ...
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CJEU decision on the Beneficial Owner concept under the Interest and Royalties Directive and the Parent-Subsidiary Directive

On February 26, 2019, the Court of Justice of the European Union (CJEU) rendered two landmark decisions on the interpretation of the beneficial owner concept in cases where the Interest and Royalties ...
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Fiscal Unity Emergency Repair Act adopted by Upper House

On April 23, 2019, the Fiscal Unity Emergency Repair Act (Wet spoedreparatie fiscale eenheid) was adopted by the Upper House. We had previously explained the bill in our memoranda dated June 7, 2 ...
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Deputy Minister announces proposed policy for renewed ruling practice

In a letter sent to the Lower House on April 23, 2019, the Deputy Minister of Finance announced the proposed policy statement, in which the measures for reforming the practice for rulings with an inte ...
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Answers to parliamentary questions about conduit companies

On February 26, 2019, the Court of Justice of the European Union (‘CJEU’) rendered two important judgments (on the anti-abuse rules in the Parent-Subsidiary Directive (PSD) and in the Intere ...
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