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).
Today, a client surprised us with this cake. It reminded us what wonderful clients we have. It has been a great first year, in which we have been able to work on fantastic projects. We thank everyone with whom we have worked in our first year!
The Dutch government published the announced bill on new loss compensation rules. The carry forward term for loss compensation will be indefinite (compared to the current term of 6 years), with a 1 year carry back term. Losses up to EUR 1m can be utilized fully. Any excess loss balance may compensate up to 50% of taxable income. The new rules apply generally for book years starting on or after 1 January 2022 (with some transitional rules for specific situations).
The bill to implement the job-related investment deduction “BIK” has been published. The BIK provides for a wage tax reduction for investments into newly acquired business assets. The BIK forms a welcome compensation for businesses contributing to the economy.