Netherlands: Tax

The EU's Taxation Omnibus proposal aims to expand the Parent-Subsidiary Directive to include pension funds and eliminate minimum ownership thresholds, potentially removing significant tax obstacles for cross-border EU investments. Meanwhile, the Netherlands has introduced temporary relief measures for collective investment vehicles (FBIs) affected by recent tax classification reforms, providing a pragmatic solution for pension funds navigating new transparency requirements.

The Dutch Ministry of Finance has issued an updated Decree providing crucial clarifications on the practical application of hybrid mismatch rules under ATAD2. These updates address key interpretative questions that have emerged in practice, particularly concerning the interaction with US tax regimes, capitalised acquisition costs, and cost-plus transfer pricing structures.

The European Commission's Tax Simplification Package proposes sweeping reforms to EU direct tax directives, promising to cut business compliance costs by EUR 8 billion annually. The draft Omnibus Directive would eliminate minimum holding requirements for withholding tax relief, ease interest deduction limitations, and introduce an EU-wide R&D allowance. With negotiations targeting conclusion in Q4 2027 and implementation by 2029, these changes could fundamentally reshape cross-border taxation for companies

Dutch tax authorities have issued new guidance clarifying the comparability criteria for foreign pension funds seeking exemptions from Dutch corporate income tax and dividend withholding tax. The guidance addresses whether minimum age and income thresholds, as well as voluntary additional contributions, prevent foreign pension schemes from qualifying for Dutch tax relief.

The Dutch Supreme Court has issued a decisive ruling on the contentious Box 3 tax assessments, determining the fate of taxpayers who failed to timely object to their assessments between 2017 and 2020. This judgment resolves a critical question left open by the landmark Christmas judgment of 2021, establishing whether non-objecting taxpayers can still claim relief. The decision carries significant implications for thousands of Dutch taxpayers who may have missed objection deadlines during this period.

Een BV opheffing kan snel en efficiënt via een turboliquidatie, maar deze procedure vereist zorgvuldige voorbereiding en naleving van strikte voorwaarden. Wat zijn de juridische en fiscale risico's van deze...

The Dutch Ministry of Finance has issued an updated Decree providing crucial clarifications on the practical application of hybrid mismatch rules under ATAD2. These updates address key interpretative questions that have emerged in practice, particularly concerning the interaction with US tax regimes, capitalised acquisition costs, and cost-plus transfer pricing structures.

The OECD's proposed revisions to Chapter VII of the Transfer Pricing Guidelines represent the most extensive rewrite of intra-group services guidance in years, introducing new requirements for accurate delineation, expanded benefit testing, and dedicated documentation standards. Loyens & Loeff's Transfer Pricing team has submitted detailed comments assessing whether these changes reduce compliance burdens or risk increasing double taxation for multinational enterprises.

European automotive suppliers are preparing the fiscal year 2025 corporate income tax returns against a sector that no longer matches the assumptions underlying their existing tax positions.

Navigating the complex real estate tax environment across the Netherlands, Belgium, Luxembourg and Switzerland requires understanding key legislative developments and structuring opportunities. This comprehensive guide examines critical tax considerations throughout the acquisition, holding and exit phases of real estate investments, while addressing recent changes to entity classification rules, withholding taxes, and investment fund regimes.

The EU's Taxation Omnibus proposal aims to expand the Parent-Subsidiary Directive to include pension funds and eliminate minimum ownership thresholds, potentially removing significant tax obstacles for cross-border EU investments. Meanwhile, the Netherlands has introduced temporary relief measures for collective investment vehicles (FBIs) affected by recent tax classification reforms, providing a pragmatic solution for pension funds navigating new transparency requirements.

The Dutch Tax Authorities have issued new guidance on the classification of limited partnerships as 'Funds for Joint Account' (FGR) under Dutch tax law, specifically addressing team co-investment...