Dutch/Curacao shipping structure

We would like to present a tax proposition for ship-owning companies using the Curacao tonnage tax system and the Dutch participation exemption. The structure combines a Dutch holding company with an subsidiary on Curacao. Both The Netherlands and Curacao have tonnage tax regimes. Under such regime the actual profit is not taxed, but the taxable … Continued

Consultation on Anti Tax Avoidance Directive published

On 10 July 2017, the Dutch government published the consultation document for implementation of the Anti Tax Avoidance Directive (ATAD1). The document outlines the potential changes to Dutch law based on ATAD1, which mainly concerns earning stripping and controlled foreign corporations. ¬†The consultation document is open for comments until 21 August 2017. Implementation of ATAD1 … Continued

Multilateral agreement against tax evasion

Recently, the multilateral treaty against international tax evasion was signed by nearly 70 countries, including the Netherlands. The treaty is one of the results of the Base Erosion and Profit Shifting project (BEPS-project) by the OECD. A number of countries intend to sign this treaty later this year. Below we explain the background and consequences … Continued

Draft published: New dividend withholding tax rules

An internet consultation of the amendment of the Dutch dividend withholding tax rules has been published. The draft proposal contains three subjects: the dividend withholding tax for cooperatives, the general withholding tax exemption and anti-abuse provisions regarding this subject are amended. The outline of the proposal is in line with the previous communications of the … Continued

EU: all hybrid mismatches targeted

This week, the EU has reached agreement on a broadening of the scope of the Anti-Tax Avoidance Directive (ATAD) to target hybrid mismatches. In the amended ATAD the various kinds of hybrid mismatches are covered and the scope is broadened to also include third country situations. We describe these amendments in more detail below.   … Continued

New dividend withholding tax rules for cooperatives

An outline of the new dividend withholding tax regulations for cooperatives was published by the state secretary of Finance. This follows the earlier announcement that the current exemption for cooperatives will be abolished (our news message). We describe this outline below.   The new regulation The Dutch government would like to impose dividend withholding tax … Continued

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