The Netherlands

Africa

OECD publishes details on 40 countries’ uptake of transfer pricing rules for hard-to-value intangibles

December 16, 2020

The OECD today published 40 responses to a questionnaire that asked officials whether their country has adopted transfer pricing rules for . . .

Europe

Netherlands resisting Russian proposal to amend tax treaty to increase withholding for dividends and interest to 15 percent: TASS→

December 9, 2020

Europe

Dutch opposition party proposes controversial dividend exit tax

September 30, 2020

Jian-Cheng Ku, Gabriël van Gelder, and Mehdi el Manouzi, DLA Piper, Amsterdam, discuss a Dutch proposal to introduce an exit tax to the dividend withholding tax which, if enacted, would apply to Dutch resident companies undertaking cross-border reorganizations as of September 18 . . .

Asia-Pacific

Vodafone wins tax dispute in international arbitration: India’s dilemma

September 29, 2020

Bijal Ajinkya, Ashish Mehta, and Krutika Chitre, of Khaitan & Co, Mumbai, discuss Telecom giant Vodafone’s win against the Republic of India in international arbitration, in a tax case involving the indirect transfer of assets, and India’s possible next steps . . .

Europe

The 2021 Dutch tax plan: key takeaways for multinational enterprises

September 28, 2020

Jian-Cheng Ku, Tim Mulder, and Xander Stubenrouch of DLA Piper, Amsterdam, discuss the Dutch government’s September 15 tax legislative proposals, focusing on the items most relevant to multinational enterprises . . .

Europe

First Look: Dutch Tax Plan 2021 released

September 15, 2020

Jian-Cheng Ku, Tim Mulder, and Xander Stubenrouch of DLA Piper Nederland N.V., Amsterdam, note today’s release of Dutch Tax Plan 2021 and highlight some of the most important provisions for multinationals . . .

Bulgaria

Bulgaria, Netherlands sign new tax treaty: The Sofia Globe→

September 14, 2020

Americas

Netherlands announces changes to tax treatment of Brazil interest on equity payments

September 7, 2020

Jian-Cheng Ku and Mehdi el Manouzi, DLA Piper Nederland N.V., Amsterdam, discuss August 27 Netherlands Ministry of Finance guidance describing the new Dutch policy with respect to the tax treatment of interest on equity payments under the Netherlands-Brazil tax treaty . . . .

Americas

OECD publishes report on tax policy reforms enacted both before and after COVID-19 in 37 OECD member countries plus Argentina, China, Indonesia, South Africa: OECD→

September 4, 2020

Europe

Unilever would not move headquarters from Netherlands if Dutch Green’s proposal for ‘exit tax’ enacted: Reuters→

August 11, 2020

Cyprus

Russia seeks to update Netherlands, Cyprus, Malta, Luxembourg tax treaty to add 15 percent withholding tax on dividends and interest: Mohammad Ali / UrduPoint→

August 10, 2020

Europe

EU Commission releases decision extending scope of State aid investigation into IKEA’s Dutch taxation

July 14, 2020

The European Commission on July 19 released a copy of its decision to widen the scope of its in-depth investigation into the Netherlands’ tax treatment of an IKEA subsidiary . . .

Europe

The Netherlands’ new DAC6 requirements: what multinationals need to know

July 8, 2020

Jian-Cheng Ku and Tim Mulder of DLA Piper Nederland NV discuss the Netherlands’ DAC6 guidance, released on June 26, and the implications for multinational group taxpayers . . .

Europe

Netherlands announces new policies for resolving cross-border tax disputes

July 7, 2020

Jian-Cheng Ku and Rhys Bane, DLA Piper Nederland N.V., Amsterdam, discuss the Netherlands government’s June 22 announcement of new policies regarding the mutual agreement procedures (MAPs) and arbitration procedures in its tax treaties . . .

Europe

Netherlands confirms extension of DAC6 rules: Mehdi el Manouzi / Twitter→

June 26, 2020

Europe

Netherlands to deny COVID-19 aid to companies located in low-tax countries or that make royalty or interest payments to low tax countries: Government of Netherlands→

June 24, 2020

Europe

Netherlands announces plans for new dividend withholding tax

June 4, 2020

Jian-Cheng Ku and Rhys Bane of DLA Piper Nederland N.V., Amsterdam, discuss the Dutch government’s May 29 announcement of its intention to propose an additional withholding tax on dividends to step up its fight against tax avoidance . . . .

Netherlands Supreme Court addresses taxation of perpetual securities under debt/equity rules

May 21, 2020

Jian-Cheng Ku, Gabriël van Gelder, and Mehdi el Manouzi, DLA Piper Nederland N.V., Amsterdam, discuss an important Netherlands Supreme Court decision published May 15 which considered whether perpetual loans should be viewed as debt or equity for tax purposes . . .

EU Commission to investigate whether Netherlands granted IKEA subsidiary State aid by approving tax deductions

May 1, 2020

The European Commission announced April 30 that it has widened the scope of its in-depth investigation into the Netherlands’ tax treatment of an IKEA subsidiary . . .

Europe

Netherlands and Germany agree on cross-border worker taxation in light of COVID-19

April 20, 2020

Jian Cheng Ku, Rhys Bane, and Mehdi el Manouzi, of DLA Piper Nederland N.V., Amsterdam, analyze a competent authority agreement executed by the Netherlands and German governments addressing the application and interpretation of Article 14 (income from employment) of the Netherlands-Germany tax treaty in light of recent measures to curb COVID-19 . . .

Europe

Italian politicians rebuke Netherlands over opposition to EU emergency aid, say Dutch corporate tax regime siphoned money away from EU states that could have helped: Zack Newmark / NL Times→

March 31, 2020

Europe

Netherlands enacts tax measures in response to COVID-19

March 19, 2020

Jian-Cheng Ku and Rhys Bane of DLA Piper Nederland N.V., discuss measures announced by the Dutch government on March 12 and March 17 in response to the COVID-19 pandemic . .

Europe

EU court assesses legality of Netherlands’ denial of German UCITS’s dividend withholding tax refund

February 11, 2020

Jian-Cheng Ku and Tim Mulder of DLA Piper Nederland N.V., Amsterdam, analyze the European Court of Justice’s January 30 decision in the Köln-Aktienfonds Deka case concerning the legality of the Netherlands’ refusal to grant a German investment fund a dividend withholding tax refund . . .

Europe

Dutch government adds two countries, removes four in 2020 update to low-tax jurisdiction list

January 15, 2020

Jian-Cheng Ku and Tim Mulder of DLA Piper Nederland N.V., Amsterdam, discuss the Dutch government’s December 18 update to its list of low-tax jurisdictions and the list’s implications for multinational taxpayers . . .

Americas

Google to end use of ‘Double Irish, Dutch sandwich’ tax loophole: Edward Helmore / The Guardian→

January 4, 2020

Europe

2020 Dutch Tax Plan passes: relevance for multinational enterprises

December 30, 2019

Jian-Cheng Ku and Tim Mulder of DLA Piper Nederland N.V., Amsterdam, provide an update on the Dutch 2020 tax plan which significantly changes the taxation of multinationals . . .

Europe

Netherlands publishes first summaries of private tax rulings issued to MNE groups

December 5, 2019

Jian-Cheng Ku and Tim Mulder of DLA Piper Nederland N.V., Amsterdam, discuss the Netherlands” publication, on October 16, of the first redacted summaries of private tax rulings . . .

Belgium

Latest EU effort to make country-by-country reporting public fails

December 3, 2019

Davide Anghileri of the University of Lausanne, Switzerland discusses a recent EU Council vote on a proposal to make public country-by-country reports on large multinationals . . .

EU finance ministers urge adoption of aviation tax

November 11, 2019

Finance ministers from 9 European nations on November 7 called on the European Commission to advance a proposal for . . .

Europe

Netherlands, UK liable for overseas territories’ unpaid customs duties, EU court concludes: The Daily Herald Newspaper St. Maarten→

November 6, 2019

Asia-Pacific

Switzerland’s Federal Council approves amendments to tax treaties with New Zealand, Netherlands, Norway, Sweden

November 6, 2019

Switzerland’s Federal Council on November 6 approved four tax treaty protocols . . .

Americas

Unanimity not required to update global rules for taxing multinational groups, OECD’s Saint-Amans says

October 18, 2019

The OECD’s “pillar one” proposal to update the global rules for allocating multinational group profit and related taxing rights can be implemented even if . . .

American Samoa

Netherlands government publishes revised draft list of low tax jurisdictions

October 8, 2019

Jian-Cheng Ku and Rhys Bane of DLA Piper, Amsterdam, discuss the Dutch government’s October 7 release of a draft list of low tax jurisdictions which makes four changes from the previous list. . . .

Europe

EU court backs use of arm’s length principle to assess Starbucks, Fiat APAs for state aid violation

September 24, 2019

The EU General Court today released long-awaited rulings in the Fiat and Starbucks tax state aid cases, concluding in both decisions that it is appropriate for the European Commission assess whether an advance . . .

Europe

Netherlands hits British American Tobacco with £902m (USD 1.1b) tax bill over fees paid for loans from UK holding company: DutchNews.nl→

September 24, 2019

Americas

France joins ICAP pilot to jointly assess MNE tax positions

September 18, 2019

France has joined the International Compliance Assurance . . .

Europe

The 2020 Dutch budget and tax plan: key takeaways for multinational enterprises

September 18, 2019

Jian-Cheng Ku and Rhys Bane of DLA Piper, Amsterdam, discuss the Dutch government’s 2020 budget and tax plan, presented September 17, which proposes modifications to the taxation of multinational firms . . .

Europe

Netherlands foreign investment fund tax regime may breach EU law, advocate general says

September 17, 2019

Jian-Cheng Ku and Rhys Bane of DLA Piper, Netherlands, discuss a September 5 opinion of the European Court of Justice Advocate General in a dispute involving the availability of Dutch dividend withholding tax refunds for foreign investment funds . . .

Americas

OECD releases “stage 2” reports on tax dispute resolution in US, UK, Belgium, Switzerland, Canada, Netherlands

August 14, 2019

The OECD on August 13 published six “stage 2” peer review reports assessing whether the United States, United Kingdom, . . .

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Emma Hinson Sims on The Pillar One blueprint — the potential future of international taxation and transfer pricing: “HAPPY BIRTHDAY TO A VERY SMART, BEAUTIFUL, YOUNG LADY ON JANUARY 13TH.” January 6 ,2024

David Valdez on US Tax Court resolves Whirlpool tax dispute involving Mexican maquiladora structure: “Greetings Whirlpool Mexico, I’m trying to contact someone involved with the decision making for transportation from all of your Mexican…” October 20 ,2023

Jose Dominguez on The new US international tax rules: what you need to know about GILTI, FDII, BEAT etc.: “Very informative article. Question. Do you have a software to compute these US International Calcs to make them in house?” April 12 ,2023

Ciro César Soriano de Oliveira on Danish High Court rules on beneficial ownership of dividends for tax purposes: “Dear Ms Susi, This article is immensely clarifying. I’d like to know whether Danish Supreme Court has already granted its…” March 24 ,2023

May 19 – 20	Tax Council Policy Institute Conference	Washington, D.C.
May 19 – 20	IFA Second European Region Conference	Milan, Italy
May 24	IFA Webinar Series Pillar Two: An Update	Virtual Event
Sept. 4 – 8	IFA Congress	Berlin