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.
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.
Changes to corporate income tax loss set-off as of January 1, 2022, BIK withdrawn
On Friday, May 28, 2021 the caretaker government announced that the changes to the corporate income tax loss set-off can take effect as of January 1, 2022. It was also announced that the Job related Investment Allowance (Baangerelateerde Investeringskorting; BIK) will be withdrawn.
Refund of Dutch dividend withholding tax based on Sofina judgment
This Decree potentially provides a meaningful option to foreign entities that have not been able to otherwise obtain relief for Dutch dividend withholding tax through either a reduced treaty tax rate or an exemption.
Year end 2020 tax accounting considerations
As the end of the year is fast approaching, many organizations will soon start preparing their year‑end financial statements. The announced 2021 Tax Plan may have a significant impact on those financials and especially the income tax position. The impact should be reflected once the 2021 Tax Plan is (substantively) enacted.
Legislative proposals on tightening CIT loss set-off and on Job-related Investment Allowance presented to Lower House
On October 5, 2020 the government presented two Memorandums of Amendment to the bill on the 2021 Tax Plan to the Lower House of Parliament. These memorandums had been announced on Budget Day.