Corporate income tax

Clarification of anti-transfer pricing mismatch rule in the case of capital contributions

On January 24, 2023 Deputy Minister of Finance Mr. Van Rij clarified in a policy statement the scope of one of the measures to combat transfer pricing mismatches.
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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.
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Upper House adopts 2023 Tax Plan package and other tax bills

On December 20, 2022 the Upper House of Parliament adopted the 2023 Tax Plan package, various other tax bills and seven tax motions. We have prepared a summary about this.
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Real estate fiscal investment institution to be abolished and changes to regimes for exempt investment institutions and mutual funds

The new rules primarily affect institutional investors, (listed) real estate funds and high-net-worth families.
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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.
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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.
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Temporary solidarity contribution by fossil fuel sector

A limited number of companies whose activities involve the extraction or refining of oil and gas (approximately 40) are expected to become subject to the solidarity levy.
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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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