The Netherlands and Malawi have signed a revised tax treaty that includes antiabuse provisions preventing the benefits of the treaty from being used solely to avoid tax, The Netherlands government said on April 23. Dutch Minister for Foreign Trade and Development Cooperation Lilianne Ploumen said that the antiabuse provisions, which relate to taxes on dividends, interest and royalties . . .
Germany and The Netherlands have agreed to immediately begin spontaneous exchange of tax information on some advance pricing agreements (APAs) and on Dutch innovation and patent box rulings, Germany’s . . .
The Netherlands State Secretary of Finance on December 1 expressed support for a UK/German agreement to put limits on preferential intellectual property tax regimes under the OECD/G-20 base erosion profit shifting plan, but said that incentives should not be limited to activities that are legally protected, such as by patent, writes EY in a December 5 tax alert. The Netherlands does not plan major revisions to its innovation box regime, EY reported. For discussion, See EY.
The Netherlands should consider adopting new tax provisions to counterbalance the increased tax burdens placed on companies from OECD/G20 base erosion and profit shifting (BEPS) plan, State Secretary of Finance Eric Wiebes said. . .
The Netherlands goverment supports expanding public release of country-by-country data beyond the extractive and banking industries to all companies, Eric Weibes, State Secretary of Finance . . .
The UK on December 23 released a consultation on draft regulations for double taxation relief for groups and entities within the charge to the UK bank levy and the Netherlands bank tax, where the Netherlands is the home state of the entity or group. See, consultation.
Tax authorities from 51 jurisdictions have signed a multilateral competent authority agreement, laying the groundwork for automatic exchange of financial account information under the OECD/G-20 Common Reporting Standard beginning 2017 . . .
The European Commission on November 14 published its preliminary opinion that an advance pricing agreement (APA) granted by the Netherlands to a Starbucks subsidiary constitutes illegal state aid. The inquiry, first announced in June, is one of four state aid investigations recently initiated by the Commission clamping down on EU states that grant sweetheart deals to . . .
The Netherlands Supreme Court on June 5 upheld a lower court decision denying an interest deduction to a Dutch holding company for interest paid to a related Mauritius company under the Dutch base erosion rules because the company did not establish sufficient business reasons for the debt, writes Loyens & Loeff in a June 8 tax alert.
The Netherlands, on June 14, ratified a tax treaty signed in 2012 between The Netherlands and Ethiopia, according to a July 15 report by Consultants International. For analysis of the treaty provisions, see Consultants International.
The legislation, released September 11 and 15 also includes provisions that reduce withholding tax on dividends that follow a cross-border merger into a Dutch company. See: Loyens & Loeff. For just the transfer pricing aspects of the bill, See: Otterspeer Haasnoot & Partners.
The Netherlands on June 22 announced it has renegotiated tax treaties with Ethiopia, Ghana, Kenya, and Zambia to add antiabuse provisions to the treaties, and said that it hopes to add antiabuse clauses to tax treaties with 23 developing nations. Moreover, talks . . .
The magnitude of profit shifting by American companies “may be significant,” a US Congressional Research Service (CRS) report has concluded. The report, released April 30, found that about 50 percent of the $1.2 trillion in overseas profit reported by American . . .
The European Commission today announced that it has determined that advance pricing agreements granted to a Starbucks subsidiary by The Netherlands and to Fiat subsidiary by Luxembourg were illegal state aid because they sanctioned the allocation of too little profit to activities in those countries and . . .
The Netherlands announced November 27 that it will appeal the EU Commission’s October 21 ruling that an advance pricing agreement (APA) granted by the Netherlands to a Starbucks subsidiary amounted to illegal State aid because it sanctioned the allocation of too little taxable profit . . .
China’s State Administration of Taxation has announced that a tax treaty and protocol signed by China and The Netherlands on May 31, 2013, will enter into force on August 31. Press release (Chinese).
The UK’s HMRC, in Customs Brief 23 issued December 11, updated its view of how UK businesses must account for VAT on intragroup supplies of services to branches that are part of VAT groups located in the Netherlands or Spain, following the European Court of Justice’s ruling in Skandia America . . .
The European Commission on October 19 asked the Netherlands to amend the limitation on benefits clause in its tax treaty with . . .
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