By Jian-Cheng Ku, Tim Mulder, & Rhys Bane, DLA Piper, Amsterdam
Following the legislative proposals published by the Dutch government on September 18, a list with jurisdictions qualifying as “low-tax jurisdictions” was published for public consultation on September 25.
This list of low-tax jurisdictions is relevant for the proposed Dutch controlled foreign company (CFC) rules that are expected to take effect on January 1, 2019, and potentially the new source tax that is expected to take effect on January 1, 2020, for dividends and January 1, 2021, for interest and royalty payments.
The list is comprised of jurisdictions that levy zero corporate income tax or that impose a statutory rate of less than 7%.
The listed jurisdictions are Anguilla, the Bahamas, Bahrain, Bermuda, the British Virgin Islands, the Cayman Islands, Guernsey, the Isle of Man, Jersey, Kuwait, Palau, Qatar, Saudi Arabia, the Turks and Caicos Islands, the United Arab Emirates, and Vanuatu.
The proposed Dutch CFC rules would apply to entities that have no substance and are resident in the countries listed on the EU list of non-cooperative jurisdictions for tax purposes or the listed low tax jurisdictions.
For more information regarding the Dutch CFC rules and source tax, read the authors’ article on the Dutch tax proposals for 2019.
–Jian-Cheng Ku is a Tax Adviser with DLA Piper, Amsterdam. He advises on international tax law and transfer pricing with a particular focus on international tax planning, M&A and private equity transactions, corporate reorganisations, and planning and design of transfer pricing policies.
-Tim Mulder is a Tax Adviser with DLA Piper, Amsterdam. Tim advises on Dutch and international tax aspects relating to international tax planning, M&A transactions, corporate restructurings, private equity and investment fund transactions.
–Rhys Bane is a Tax Adviser with DLA Piper, Amsterdam. Rhys advises on Dutch corporate taxation and international tax law, with a focus on international tax planning, corporate restructurings and Dutch, European and international tax policy & legislation.
Jian-Cheng Ku
Jian-Cheng Ku advises on international tax law and transfer pricing with a particular focus on international tax planning, M&A and private equity transactions, corporate reorganisations, and planning and design of transfer pricing policies.
Latest posts by Jian-Cheng Ku (see all)
- Dutch committee presents report on conduit companies and associated tax policy options - December 1, 2021
- Dutch 2022 budget approved by House of Representatives, moves to Senate - November 22, 2021
- Netherlands issues policy decree clarifying hybrid mismatch tax measures - October 25, 2021
- Dutch 2022 budget plan includes tax proposals on transfer pricing, hybrids - September 27, 2021
- Netherlands legislative proposal tackles transfer pricing mismatches - March 24, 2021
Jian-Cheng Ku
Partner
T +31205419911
F +31 20 541 9999
M +31613384683
E [email protected]
DLA Piper Nederland N.V.
Amstelveenseweg 638
1081 JJ Amsterdam
P.O. Box 75258
1070 AG Amsterdam
The Netherlands
Tim Mulder
Latest posts by Tim Mulder (see all)
- Netherlands legislative proposal tackles transfer pricing mismatches - March 24, 2021
- The 2021 Dutch tax plan: key takeaways for multinational enterprises - September 28, 2020
- First Look: Dutch Tax Plan 2021 released - September 15, 2020
- The Netherlands’ new DAC6 requirements: what multinationals need to know - July 8, 2020
- EU court assesses legality of Netherlands’ denial of German UCITS’s dividend withholding tax refund - February 11, 2020
Rhys Bane
Rhys Bane advises clients on Dutch and international tax aspects of international (tax) structuring and corporate reorganizations, Dutch, European and international tax policy matters and on tax controversy matters.
Rhys Bane is also a PhD candidate at Leiden University. His doctoral research focuses on international tax arbitration.
Latest posts by Rhys Bane (see all)
- Dutch committee presents report on conduit companies and associated tax policy options - December 1, 2021
- Dutch 2022 budget approved by House of Representatives, moves to Senate - November 22, 2021
- Netherlands issues policy decree clarifying hybrid mismatch tax measures - October 25, 2021
- Dutch 2022 budget plan includes tax proposals on transfer pricing, hybrids - September 27, 2021
- Netherlands adds new minimum substance requirements to conditional withholding tax anti-abuse rule - February 17, 2021
Rhys Bane
Tax Advisor
T +31 20 541 9392
F +31 20 541 9999
M +31 6 1562 3924
E [email protected]
DLA Piper Nederland N.V.
Amstelveenseweg 638
1081 JJ Amsterdam
P.O. Box 75258
1070 AG Amsterdam
The Netherlands
www.dlapiper.nl
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