Decree on US-NL tax treaty abolished

The formal Decree abolishing access to the US-NL tax treaty for reverse hybrid entities (such as certain CVs) per 1 January 2020 has been published. The Decree is in line with an earlier announcement and clarifies that existing rulings or permits will not be grandfathered. In addition, the March 1997 Decree granting treaty access to hybrid recipients will be reconsidered (potentially resulting in double taxation). This can be seen in the context of a wider reconsideration of Dutch transparency criteria.