Corporate income tax

Good Practices Tax Control Framework: next steps

In its webinar on January 13, 2022, the Dutch Tax and Customs Administration, in collaboration with the Dutch Association of Tax Advisors, provided further details on the background to the Good Practices Tax Control Framework and elaborated on how to apply these good practices in real-world situations.

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European Commission publishes proposal for a directive to tackle the misuse of shell entities

On December 22, 2021 the European Commission published a proposal for a directive aimed at preventing the misuse of shell entities and arrangements for tax purposes (hereinafter: the directive).

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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 have a broader scope that includes large-scale purely domestic groups.

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Upper House of Parliament adopts the 2022 Tax Plan package and the bill on Combating mismatches in the application of the arm’s length principle Act

We have briefly outlined the motions that were approved.

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OECD publishes Global Anti-Base Erosion Model Rules (Pillar 2)

On December 20, 2021 the OECD published the Global Anti-Base Erosion (‘GloBE’) Model Rules, also known as Pillar 2. The GloBE Rules aim to impose a global minimum tax of 15% on multinational enterprises with a revenue in excess of EUR 750 million.

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Good Practices Tax Risk Management

Practical examples showing how an organization can deal with different elements of the Tax Control Framework (TCF).

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Tax aspects of 2021 coalition agreement

We briefly address what is currently known about the intended tax measures.

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Internet consultation on dividend stripping

In practice, substantial (albeit not easily quantifiable) amounts in dividend tax are avoided via various forms of dividend stripping, which the Dutch tax authorities cannot properly combat with the current legal instruments. The consultation document contains six potential solutions.

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Private member’s bill on conditional final settlement of dividend withholding tax radically amended

Although the essence of the bill has remained the same, the 4th Memorandum of Amendment contains several essential changes to the scope and the tax methodology.

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