Netherlands announces tax policy agenda for 2019

By Jian-Cheng Ku & Rhys Bane, DLA Piper, Netherlands

The Dutch government on May 29 announced its priorities and timelines in the area tax policy, including how the Netherlands intends to deal with tax evasion and tax avoidance and improve the Dutch investment climate.

Tax evasion and tax avoidance

According to, Fiscale beleidsagenda 2019, prepared by the Netherlands State Secretary of Finance, future legislation and policy priorities include the implementation of the EU anti-tax avoidance directive II, which targets hybrid mismatches; the introduction of a conditional withholding tax on interest and royalties;  renewing the Dutch tax ruling practice, and implementing the EU mandatory disclosure directive.

The legislative proposal implementing the EU anti-tax avoidance directive II is expected to be published this month. The other measures will be proposed in the third quarter, including on budget day, which is September 17, 2019.

The  State Secretary of Finance notes that the Netherlands has recently introduced a number of measures to counter tax evasion and tax avoidance, including the implementation of the EU Anti-Tax Avoidance Directive I, the ratification of the Multilateral Instrument, the introduction of a list of low tax jurisdictions to which additional controlled foreign company (CFC) rules apply, and the introduction of legislation that applies to trust offices.

Dutch investment climate

The agenda notes that the Netherlands’ investment climate is very attractive for several reasons, such as the infrastructure, geographical positioning (as a gateway to Europe), the level of education of the working population and the reliability y of government and the innovative ecosystem.

The State Secretary of Finance also notes the lowering of Dutch corporate income tax rates makes the Netherlands more attractive for companies in general and indicates that measures will be taken in the area of Dutch wage tax to make it more attractive for startups and scale-ups to pay their employees in stock options.