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.
Internet consultation on tax treaty policy and designation of low-taxed states
On September 25, 2018 the government launched an internet consultation, giving interested parties the opportunity to raise issues that are important to them relating to i) Dutch tax treaty policy and ii) the designation of low-taxed states with a view to – first of all – the application of the measure on Controlled Foreign Companies (‘CFC’s’) proposed on Budget Day.
We will briefly address these two aspects of the consultation