Netherlands Tax News
Bill to simplify limited liability company legislation published
Compatibility of exclusion of indirect ownership through companies in other EU Member States for French tax consolidation purposes with freedom of establishment referred to ECJ
Treaty between the Netherlands and Barbados enters into force
OECD releases revised draft of Part IV (Insurance) of the Report on Attribution of Profits to Permanent Establishments
AG: Most-favoured nation treatment and Community preference do not require extension of the tax sparing credit under tax treaties with Brazil and Greece to third countries
Lower Court of The Hague decided parent company of group not holding company for purposes of Tax Regulation of the Kingdom
New agreement on organizations eligible for benefits under Art. 35 of Netherlands-US treaty signed
EU Commission refers Greece to ECJ concerning discriminatory taxation of dividends
Second Guideline on implications of ECJ Denkavit case on French dividend withholding tax published
EU Commission progresses infringement procedure against Austria, Germany, Italy and Finland regarding taxation of outbound dividends
Netherlands restriction on loss compensation under transitional regime compatible with treaty between Netherlands and Italy, EC fundamental freedoms, ECHR Treaty
ECJ: Finnish group contribution regime compatible with EC Law – details
Upper House adopted bill on introduction of new investment fund regime and amendments to existing regime
Treaty between Belgium and Netherlands – Court of Appeal Ghent holds stock of goods does not constitute PE
Implementation Bill on fiscal aspects of partnerships submitted to parliament
ECJ: Interprets anti-avoidance clause under the Merger Directive with respect to Danish rules on taxation of exchanges of shares – details
ECJ: Swedish legislation on dividend tax relief in relations with third countries is compatible with EC law – details
ECJ: Advocate General holds German switch-over provision for low-taxed passive income of foreign PEs incompatible with EC Law – details
ECJ: Advocate General finds Dutch withholding tax on outbound dividends incompatible with EC free movement of capital – details
ECJ: Previous Austrian rules discriminating dividends received from third countries are compatible with free movement of capital under grandfathering clause – details
Agreement between the Netherlands and Jersey on mutual agreement procedures concerning profit adjustment and application of Netherlands participation exemption signed
ECJ: German thin capitalization rules reclassifying interests paid to substantial shareholders in third States are not incompatible with EC law
Treaty between the Netherlands and United Arab Emirates – details
Implementing rules for avoidance of double taxation on dividends under tax treaties published
Dutch Supreme Court decides that Netherlands not obliged to grant credit for Brazilian and Italian withholding tax on interest derived by Belgian PE of Dutch company
International tax conference on CCCTB held in Berlin
Discussion draft on application and interpretation of non-discrimination article of OECD Model – details
Treaty between Netherlands and Switzerland – negotiations
Revised Commentary on Article 7 of OECD Model released
Further reduction of corporate income tax rate announced
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