The Netherlands

Asia-Pacific

Singapore’s tax treaties with Netherlands and Georgia amended

July 1, 2019

The Inland Revenue Authority of Singapore has announced that amendments . . .

Americas

Uber generated $6.1 b Dutch tax deduction by transferring IP with increased value from a Bermuda sub to Dutch sub controlled by Singapore company: Lynnley Browning & Eric Newcomer / Bloomberg→

August 12, 2019

Europe

Netherlands draft tax law targeting hybrid mismatches includes new documentation requirement

July 7, 2019

Mehdi el Manouzi and Michiel Moison of PwC Netherlands discuss the Dutch government’s July 2 legislative proposal implementing the EU rules targeting hybrid mismatches . . .

Europe

Dutch government to promote EU-wide carbon pricing, aviation taxes at two-day conference: Netherlands government→

June 20, 2019

Europe

EU Commission’s publishes decision to probe whether Netherlands tax rulings granted State aid to Nike

July 5, 2019

The EU Commission this week released. . .

Europe

Netherlands proposes four options for revising corporate tax group regime

June 20, 2019

Jian-Cheng Ku and Rhys Bane of DLA Piper Nederland N.V. discuss a June 17 consultation launched by the Dutch State Secretary of Finance outlining possible approaches for a new corporate tax group regime in the Netherlands . . .

Europe

Netherlands announces tax policy agenda for 2019

June 12, 2019

Jian-Cheng Kua and Rhys Bane of DLA Piper, Netherlands, discuss the Dutch government’s May 29 announcement of priorities and timelines in the area tax policy . . .

Asia-Pacific

Iraq, Netherlands sign tax treaty: Sangar Ali / Kurdistan24→

July 1, 2019

Europe

Switzerland and Netherlands sign protocol amending tax treaty

June 12, 2019

Switzerland and the Netherlands have signed a protocol of amending their tax treaty . . .

Asia-Pacific

BEPS multilateral tax treaty to enter into force for Ukraine

August 8, 2019

Ukraine today deposited with the OECD legal documents ratifying . . .

Europe

Netherlands establishes expert commission to examine how to make multinational taxation “more fair”: John O’Donnell & Toby Sterling / Reuters→

June 12, 2019

Europe

Netherlands draft law requires disclosure of cross-border transactions to tax authorities

July 22, 2019

Jian-Cheng Ku and Rhys Bane of DLA Piper Nederland N.V. discuss a July 12 Netherlands government proposal requiring intermediaries and, in some cases, taxpayers, to report cross-border arrangements that meet certain hallmarks to the tax authorities. . . .

Europe

Shell reveals that only one of its subsidiaries paid tax in Netherlands where the group is headquartered, prompting calls for tax avoidance hearing: Reuters→

May 21, 2019

Europe

Dutch parliament committee to “forcefully” ask Shell to attend tax avoidance hearing: Reuters→

April 10, 2019

Europe

First Look: Germany, Netherlands release joint statement on tax avoidance, minimum tax: Netherlands Ministry of Finance→

March 27, 2019

MNE Tax will publish an in-depth article about this development shortly.

Europe

Nike tax rulings under EU Commission scrutiny

January 11, 2019

Dr. Patricia Lampreave, an EU tax and state aid expert and professor at the Instituto de Estudios Bursátiles, Madrid, discusses the EU Commission’s announcement yesterday of an investigation into tax rulings granted by the Dutch tax authorities to Nike group companies . . .

MEP asks EU Commission to investigate whether Shell/Netherlands merger deal avoiding dividend tax was EU State aid: DutchNews.nl→

June 18, 2018

Asia-Pacific

India, Netherlands negotiating tax treaty amendment to plug share transfer loophole: Gireesh Chandra Prasad / LiveMint→

April 10, 2019

Africa

IMF paper concludes African countries worse off for signing tax treaties with “investment hubs” like Mauritius

October 26, 2018

African countries that signed tax treaties with Mauritius and other nations considered to be “investment hubs” did . . .

Europe

Netherlands reveals plan for new withholding tax regime, increased substance requirements

March 5, 2018

Jian-Cheng Ku and Tim Mulder of DLA Piper, Amsterdam, discuss new Dutch government proposals for a conditional withholding tax on royalties, interest, and dividends and increased substance requirements for Dutch holding, license, and financing companies . . .

Americas

EU Parliament adopts controversial report on tax avoidance and evasion

March 27, 2019

Davide Anghileri of the University of Lausanne, Switzerland, writes that the EU Parliament endorsed a report March 26 that calls out seven member states for their role in facilitating aggressive tax planning and recommends countermeasures against the US should it fail to provide FATCA reciprocity . . .

First Look: EU investigating Netherlands tax rulings granted to Nike for state aid violations

January 10, 2019

The European Commission today announced that it has opened in-depth investigations into tax . . .

Europe

Netherlands proposes temporary changes to tax consolidation regime to comply with EU law

June 13, 2018

Jian-Cheng Ku and Tim Mulder, DLA Piper, Amsterdam discuss a Netherlands Ministry of Finance legislative proposal published June 6 that contains emergency measures to bring the Dutch tax consolidation regime in line with EU law . . .

Europe

Dutch tax consolidation tax regime violates EU law, court rules

February 22, 2018

Jian-Cheng Ku and Tim Mulder of DLA Piper, Amsterdam, discuss the implications of a European Court of Justice (ECJ) decision released February 22 which concludes that the Dutch tax consolidation regime (fiscal unity) violates EU law . . .

Europe

Netherlands deposits MLI ratification instrument with OECD after opting out of PE rule

April 1, 2019

Jian-Cheng Ku and Rhys Bane of DLA Piper Nederland N.V. note that the Netherlands on March 29 deposited its instrument of ratification of the BEPS MLI with the OECD and discuss the clauses that the Netherlands opted to adopt . . .

Europe

The 2019 Dutch budget and tax plan: key takeaways for multinational enterprises

September 26, 2018

Jian-Cheng Ku, Tim Mulder, and Rhys Bane of DLA Piper, Amsterdam, discuss the 2019 Dutch budget and tax plan, presented by the Dutch government on September 18, which proposes significant modifications to the taxation of multinational firms . . .

Europe

Tax professor Sjoerd Douma joins University of Amsterdam

September 27, 2017

Sjoerd Douma has been appointed professor of International and European Procedural Tax Law at the University of Amsterdam’s (UvA) Faculty of Law, UvA announced today. Professor Douma, who will take up his duties . . .

Europe

Netherlands tax director steps down

January 17, 2017

The Netherlands’ Director of General Tax Administration, Dr. JAJ (Hans) Leijtens, has resigned his post, the Netherlands government
. . .

Americas

OECD tax officials visit Cayman after Dutch tax blacklisting, “One should first think about what a tax haven is, before putting that label on the Cayman Islands,” says Pascal Saint Amans: Cayman Islands Financial Services→

January 14, 2019

Prior coverage: MNE Tax

Europe

Dutch state secretary clarifies Netherlands-Germany joint declaration on conditional withholding tax, minimum tax rate

April 1, 2019

Jian-Cheng Ku & Rhys Bane of DLA Piper Nederland N.V. discuss statements made by the Netherlands State Secretary of Finance, Menno Snel, that clarify the March 27 Netherlands-Germany joint declaration on international tax matters . . .

Africa

New CIAT database tracks BEPS implementation in 36 countries

February 22, 2019

The Inter-American Center of Tax Administrations (CIAT) on February 21 released . . .

Americas

Google shifted USD 23 billion income to tax haven Bermuda in 2017 using Dutch shell company: Reuters→

January 4, 2019

Europe

Dutch court puts burden of proof on tax authority in transfer pricing case because taxpayer prepared documentation: Baker McKenzie→

October 20, 2017

Belgium

MLI choices made by the Netherlands, Belgium, Luxembourg and Switzerland: Loyens & Loeff→

June 15, 2017

Europe

New Dutch guidance addresses dividend withholding tax refund due foreign shareholders

May 5, 2016

Wiebe Dijkstra and Klaas Versteeg of De Brauw Blackstone Westbroek, Amsterdam, discuss new Dutch guidance on withholding tax refunds due foreign shareholders following the Dutch Supreme Court’s decision in Miljoen, X, and Société Général . . .

Europe

Netherlands Supreme Court rules on tax deductiblity of intercompany interest, tax penalites: Loyens & Loeff→

April 21, 2017

Americas

US tax officials discuss coming country-by-country reporting guidance, treaties, other initiatives

December 19, 2016

The US intends to release tax guidance on country-by-country reporting for MNEs that addresses reporting for LLCs in US groups and for tiered partnerships, officials said at a December 15-16 tax conference. Officials also discussed just-released final regs on outbound transfers of goodwill, US tax treaty negotiations, and the pending EU State aid. . .

Europe

Dutch taxation of multinationals: a 2017 year-in-review and look forward to the future

January 8, 2018

Jian-Cheng Ku, Tim Mulder, and Rhys Bane of DLA Piper, Amsterdam, write that 2017 was a year of significant change for Dutch tax law and international tax law; the authors predict that 2018 will be just as dynamic . . .

Europe

Dutch tax consolidation regime violates EU law, advocate general concludes

November 7, 2017

Jian-Cheng Ku, Tim Mulder, and Rhys Bane of DLA Piper, Amsterdam, discuss the CJEU Advocate General’s opinion, delivered October 25, concluding that, following the Groupe Steria decision, aspects of the Dutch tax consolidation regime violate EU concepts of freedom of establishment and are thus contrary to EU law . . .

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May 19 – 20	Tax Council Policy Institute Conference	Washington, D.C.
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