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.
The OECD published a consultation on Pillar 1’s Amount A. Amount A defines income to be attributed to market jurisdictions. A consultation on Amount B (remunerating sales&marketing activities) is expected mid-2022.
Today, the Dutch government issued a decree on the anti-hybrid rules (ATAD2). The decree confirms that the dual inclusion escape may apply for two specific situations involving (a.) a Dutch entity in a US REIT structure and (b.) a Dutch entity classifying as ‘partnership’ from a US tax perspective.
A bill has just been published to amend the Dutch tax plans per 2022. The headline CIT rate will increase to 25.8% (vs 25% today) and the earnings stripping rule will be tightened by decreasing the EBITDA percentage to 20% (vs 30% today).