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.
FS Tax Newsletter | August 2020
In this edition of the FS Tax newsletter we discuss two important judgments by the Court of Justice of the European Union in VAT cases: firstly, in the A Oy case, the Court established that co-location services do not constitute the leasing of or service attributable to immovable property. Secondly, in the BlackRock case, the Court confirmed that the provision of a single management service is not partially VAT-exempt.
FS Tax Newsletter | June 2020
In this edition of the FS Tax Newsletter we address two developments initiated by the Dutch tax authorities: the further development of horizontal monitoring and the cancellation of rulings confirming the VAT exemption for investment management services provided to CLOs. We also discuss four other VAT-related subjects: an interesting judgment from the Court of Appeals Den Bosch regarding the VAT recovery methodology of a financial institution, the opinion of the Advocate General of the Court of Justice of the European Union on the VAT treatment of purchased investment management services that are used for both Special Investment Funds as well as non-Special Investment Funds, a judgment by the Noord-Holland District Court on the VAT position of a company pension fund, and recent developments with respect to the term ‘fixed establishment’ for VAT purposes