NL Tax Alert: ATAD2 decree updated for cost-plus situations
Yesterday, an updated ATAD2 decree has been published providing relief for a common situation in which anti-hybrid rules (ATAD2) resulted in double taxation.
NL Tax Alert: Budget Day proposals
Today is budget day in NL with several tax proposals published. Some highlights, read more...
NL Tax Alert: Supreme Court (SC) raises preliminary questions to the ECJ on interest deductibility rules (article 10a) following the Lexel AB case
Today, the SC ruled that the application of article 10a CITA 1969, in cases where intercompany loans are used to finance the external acquisition of shares, is in its view compatible with EU law.
Two rulings regarding interest deductions on debts in a private equity funded acquisition structure.
Last Friday, the Dutch State Secretary of Finance advised against a member's bill regarding an exit tax in the dividend withholding tax by way of a well-motivated letter.
NL Tax Alert: New jurisprudence on interest deduction rules
Today, the Dutch Supreme Court issued two rulings regarding interest deductions on debts in a private equity funded acquisition structure.
NL Tax Alert: New TP and profit allocation decrees
Today, the Dutch government published updated decrees on Transfer Pricing (TP) and on the attribution of profits to a permanent establishment (PE).
NL Tax Alert: new stock option taxation rules adopted
Yesterday, the Dutch House of Representatives passed a bill to defer the moment employee stock options are taxed. Under the new rules, stock options are taxed when the underlying shares become tradable.
NL Tax Alert: 20a does not apply to unrealized losses
Recently, a District Court ruled on the application of art. 20a CIT Act in case of unrealized losses. The decision is relevant for M&A transactions involving a target company with unrealized losses.
Dutch Spring Memorandum (Voorjaarsnota) published
On 20 May 2022, the Dutch Ministry of Finance published its Spring Memorandum (Voorjaarsnota) containing i.a. the following tax revenue-generating proposals for 2023.
European Commission proposes tax incentive for equity
On 11 May 2022, the European Commission published a proposal for a new Council Directive that aims to encourage businesses to attract equity funding instead of debt.