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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 this.

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.

The changes will have a major impact on all organizations with holding activities and action will need to be taken before July 1, 2025.

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

The draft act on the abolishment of transfer and pledge restrictions was approved by the Dutch House of Representatives (the Act) on 11 June 2024. After the Act comes into force, it will no longer be possible for certain contracting parties to enter into agreements limiting or excluding the transferability or pledgeability of certain commercial claims. Therefore, the Act will increase the possibilities for transferring or creating a pledge over commercial claims.

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

The gross monthly salaries that apply as of January 1, 2025 have been published. For the coming year, the salary criterion will be increased by 6.70%.

Organizations are increasingly finding themselves involved in tax disputes with tax authorities. This is happening in the Netherlands, but also elsewhere.

Companies that operate at the international level will automatically be confronted with transfer pricing. The rules on this are constantly expanding, while tax authorities have also become stricter in monitoring compliance. What should you do if you land up in a dispute about transfer pricing?