International Tax Law News

Bill on Minimum Profit Tax Act 2024 (Pillar 2) presented to Lower House of Parliament

The Netherlands is thus the first EU Member State to have submitted a bill to transpose EU Directive 2022/253 of December 14, 2022 into national legislation.

2023 Guidelines on Mandatory Disclosure Rules (DAC6) published

The updated Guidelines include several substantive changes compared to the earlier version.

Pillar 2 Developments

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

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

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

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

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.

CJEU annuls Commission decision on Luxembourg transfer pricing ruling

The decision of the Court of Justice of the European Union brings key clarifications with regard to the choice of a reference system in transfer pricing State aid reviews.

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

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

Internet consultation on legislative proposal to implement Pillar 2 in the Netherlands

The legislative proposal aligns with the proposed EU Directive; in this respect, it is largely similar to the OECD Global Anti-Base Erosion (‘GloBE’) Model Rules.

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