Corporate income tax

Upper House adopts 2020 Tax Plan package and bills on ATAD2 and DAC6

Along with the adoption of the 2020 Tax Plan package and the bills on the implementation of ATAD2 and DAC6, the Upper House also adopted several motions.

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KPMG submission on ‘Pillar One’ approach to address digital economy tax issues

This week KPMG submitted its comments to the Organisation for Economic Co-operation and Development (OECD) consultation with regard to the unified approach under Pillar One.

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Limitation of liquidation and cessation loss rules for corporate income tax purposes (October 2019 update)

As we previously reported, the government intends to amend the liquidation and cessation loss rules for corporate income tax purposes as of 2021, in order to prevent improper use and to widen the tax base.

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FS Tax Newsletter Issue 28| April 2017

In this edition you will find, among others, a summary of our annual FS VAT seminar and a summary of the recently published decree on insurance premium tax. We have also included an update of relevant jurisprudence relating to VAT.

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FS Tax Newsletter Issue 27 | Februari 2017

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EU Anti-Tax Avoidance Directive 2: hybrid mismatches with third countries

On February 21, 2017 the EU Member States reached agreement on a Directive that will amend the Anti-Tax Avoidance Directive (Council Directive (EU) 2016/1164 of July 12, 2016, ’ATAD 1’). The new Directive (‘ATAD 2’) amends Article 9 of ATAD 1, which covered certain hybrid mismatches between EU Member States. 

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Country-by-Country Reporting – Additional rules for exchanging Country-by-Country reports and OECD update

On January 17, 2017 a bill to implement Council Directive (EU) 2016/881 (‘DAC4’) concerning Country-by-Country Reporting (‘CbCR’) was presented to the Lower House of the Dutch Parliament. Please refer to our previous memorandum on this. On March 21, 2017 the Memorandum of Amendment (Nota van Wijziging; ‘NvW’) and the Memorandum in response to the Report (Nota naar aanleiding van het Verslag; ‘NaV’) were sent to the Lower House. On April 18, 2017 the Lower House adopted the bill (34 651) and an amendment (no. 13) on the maximum penalty. 

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US tax reform - Trump administration announces tax reform principles

On April 26, 2017, US Treasury Secretary Mnuchin and US National Economic Council Director Cohn announced the “core principles” of President Trump’s plan for US tax reform. They said the Trump Administration is working with the House and the Senate on details and on turning the plan into legislation, with the goal of moving as quickly as possible.

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Proposed changes to dividend withholding tax open for public consultation

We previously informed you about the proposed changes to remove the way in which profit distributions by cooperatives (in principle not subject to dividend withholding tax) and private limited liability companies (BVs)/public limited companies (NVs) (in principle, subject to tax) are currently treated differently for tax purposes. On May 16, 2017 the previously announced bill on the ‘Withholding obligation for holding cooperatives and expansion of the withholding exemption Act’ (hereinafter: the draft bill) was opened for public consultation.

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