26 January 2023

Assets transferred from subjectively exempt entities to Dutch taxpayers, are out of scope of the transfer pricing mismatch rules

Dutch Ministry of Finance provides welcome guidance for tax exempt entities such as pension funds in new policy decree 
24 January 2023

The EU finally agrees on Pillar 2 rules, which calls for action

On December 15, 2022, the EU Member States unanimously agreed to implement the minimum taxation component of the OECD’s reform of international taxation, known as Pillar 2. The instrument to implement the Pillar 2 rules at the EU level is to be...
18 January 2023

DAC7 is here: Ensure readiness is key

The DAC7 directive (EU Directive 2021/514) is the latest initiative in the field of tax transparency that extends reporting requirements to digital platforms. DAC7 requires digital platform operators to report certain information about the ‘...
23 December 2022

New Dutch Decree dealing with Dutch withholding taxes in (US) hybrid structures favorable for NL-US groups

The Dutch Dividend Withholding Tax Act (“DDWT ACT”) and the Dutch Conditional Withholding Tax Act (“CWT ACT”) on interest and royalties both contain specific clauses when payments (dividend, interest or royalties) are made by a Dutch entity to a...
13 December 2022

The EU finally agrees on Pillar 2 (global minimum tax) rules, which calls for action

On December 12, 2022, the EU Council press office announced a deal to implement the minimum taxation component, known as Pillar 2, of the OECD’s reform of international taxation. Hungary was the last EU member to block the agreement. After...
12 December 2022

VAT in the Digital Age

On 8 December 2022, the European Commission published the proposals to amend the VAT Directive and other related legislation with respect to the VAT in the Digital Age ('ViDA'). It is the intention that most changes will enter into force as of 1...
29 November 2022

Upcoming changes to tax treatment of share options

For Dutch wage tax purposes, benefits from share option (plans) are currently taxed at exercise. The taxable amount for wage tax purposes is the difference between the exercise price (if any) and the fair market value of the option at exercise.
21 November 2022

Social security position for frontier workers extended (again)

What is it all about? - Based on the main rule within EU/EEA regulations, employees who work at least 25% in their country of residence are insured under the social security system of their country of residence.
10 November 2022

New Dutch ATAD2 Decree resolves overkill in certain US - NL cost-plus situations

On November 3, 2022, the Dutch State Secretary of Finance published a new decree (“Decree”) on the interpretation of the Dutch anti-hybrid rules ("ATAD2").
8 November 2022

New tax reporting rules require multinationals to reconsider their privacy governance

Due to the new tax reporting rules affecting digital platform operators, securing personal data of customers is a key aspect to ensure compliance. The new reporting rules will require that privacy and security is addressed at governance level. In...
31 October 2022

Why behavior can be an inhibiting factor in sustainable transitions and what to do about it

The need to transition to a sustainable economic system is increasing by the day. Businesses will have to play their part, and many are developing strategies for this. Yet, these rarely get implemented the way they were intended because employee...