International Tax Law News

European Commission’s response to the OECD Pillar 2 model rules

On December 22, 2021, the European Commission published a proposed EU directive to incorporate Pillar Two into EU law. The rules generally mirror the OECD model rules released on December 20, 2021 but ...

Supreme Court sets aside current Box 3 tax

The judgment affects the years from 2017 onward and may have consequences for thousands of taxpayers.

Report of the Conduit Companies Committee

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

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 ...

Internet consultation on taxpayer status measure for reverse hybrid entities

On March 4, 2021 the Deputy Minister of Finance launched, among other things, a public internet consultation on the taxpayer status measure for ‘reverse hybrid entities’ and several related accompanyi ...

New policy statement on VAT fixed establishments

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.

Dutch Supreme Court decision on Dutch withholding tax on dividends paid to foreign investment funds

The Supreme Court ruled that its earlier judgments from 2013 and 2015 were an incorrect interpretation of EU law and that foreign investment funds should be entitled to a refund of the Dutch dividend ...

New questions to CJEU: towards a broader concept of fixed establishment for VAT purposes?

A Romanian Court recently sought a preliminary ruling from the Court of Justice of the European Union (‘CJEU”) about the concept of fixed establishment for VAT purposes in the Berlin Chemie case (C-33 ...

Internet consultation on the Introduction of a conditional withholding tax on dividends Act

On September 25, 2020 the government launched an internet consultation to give interested parties the opportunity to respond to the draft bill to introduce a conditional withholding tax on dividends a ...

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