The Netherlands
EU court asked if Dutch can deny foreign fund dividend withholding tax refund
The Dutch Supreme Court has asked the Court of Justice of the European Union to resolve two separate disputes concerning whether the Netherlands can deny foreign investment funds refunds of the Dutch dividend withholding . . .
Dutch Tax Plan 2017: what will change for business?
Wiebe Dijkstra and Peter Spijker of De Brauw Blackstone Westbroek, Amsterdam, discuss tax changes in the Netherlands government’s 2017 Budget that affect multinational businesses, international investors, and investment funds . . .
Tax treaty requires Netherlands to extend fiscal unity regime to Dutch companies owned by foreign parent, court rules
Wiebe Dijkstra and Klaas Versteeg of De Brauw Blackstone Westbroek, Amsterdam, analyze a Dutch Court of Appeal decision which requires the Netherlands to extend its fiscal unity-regime to Dutch companies that have foreign parents resident in Israel or resident in countries that have a tax treaty with a nondiscrimination clause similar to that in the Netherlands/Israel tax treaty. . .
No withholding tax exemption for dividends paid to Dutch UCITS parent, court rules
Dublin-based tax specialist, JP Canavan, discusses a March 8 ruling of the Court of Justice of the European Union which concludes that dividends paid by a Belgian subsidiary to its parents, both Dutch UCITS, do not qualify for an exemption from Belgian withholding tax under the EU Parent-Subsidiary Directive . . .
Multinationals asked to assess MAP tax dispute resolution in US, UK, Belgium, Canada, Netherlands, Switzerland
The OECD has today asked international business to report grievances about the mutual agreement procedure (MAP) for resolving cross-border tax disputes in the US, UK, Belgium, Canada, Netherlands, and Switzerland. The OECD seeks responses to a . . .
US has agreed to country-by-country tax info exchange with 11 countries, OECD says
The United States has so far put in place 11 bilateral competent authority arrangements for the automatic exchange of country-by-country reports, the OECD reported a June 22 release. The US now has . . .
EU proposal to halt multinational tax avoidance through third-country hybrid mismatches stalls
EU finance ministers, during an ECOFIN meeting of the Council of the EU held December 6, were unable to reach agreement on new hybrid mismatch rules designed to prevent multinationals from avoiding tax by exploiting differences between the tax systems of EU and non-EU countries. The ministers disagreed with a Dutch proposal to extend the effective date of the rules and a UK proposal. . .
Netherlands and Switzerland agree on tax treatment of investment vehicles under tax treaty
Wiebe Dijkstra, Frank Pötgens, and Klaas Versteeg, of De Brauw Blackstone Westbroek, Amsterdam, analyze two mutual agreements recently concluded between the Netherlands and Switzerland concerning the taxation of collective investment vehicles, arguing that one of the agreements inappropriately prevents taxpayers from accessing the benefits of the Dutch-Swiss tax treaty . . .
OECD publishes peer review reports on tax dispute resolution in US, Belgium, Canada, Netherlands, Switzerland, UK
The OECD has today published peer review reports that critique the tax treaty dispute resolution process of six countries: United States, Belgium, Canada, the Netherlands, Switzerland, and the United Kingdom. The peer review was conducted by the “Inclusive Framework on BEPS,” comprised of over 100 countries that have pledged to . . .
EU investigating private tax deal granted to IKEA by Netherlands
The European Commission on December 18 opened another State aid investigation into private tax rulings granted by an EU nation to a large multinational – this time the focus on whether the Netherlands grated special tax treatment to an IKEA subsidiary. The Commission is investigating Dutch tax rulings . . .
EU Commission calls out harmful tax practices in Belgium, Cyprus, Hungary, Ireland, Luxembourg, Malta, Netherlands
The EU Commission took tentative steps toward reducing harmful tax competition among EU member countries today, publishing European Semester country reports that identify seven EU countries as potentially facilitating tax avoidance by multinationals. The Commission today also released a taxation paper detailing economic evidence that suggests that particular tax avoidance structures , , ,
Taiwan offers VAT refund to some foreign enterprises without fixed place of business
Taiwan’s taxation office announced Monday that foreign enterprises and other entities from specified countries that have no fixed place of business in Taiwan but engage in. . .
Netherlands proposes further limits on private equity investor interest deductions
International tax experts, Wiebe Dijkstra and Klaas Versteeg of De Brauw Blackstone Westbroek, Amsterdam, analyze a proposed Netherlands tax law that would tighten rules designed to prevent excessive leveraging of acquisitions of Dutch companies by private equity investors . . .