Netherlands: Tax Treaties

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Tax law and international tax law thought leadership, articles, podcasts, videos and webinars from expert sources across the legal world. Explore insights covering topics such as capital gains tax, corporate tax, income tax, inheritance tax, national insurance, property taxes, sales taxes, VAT, GST, tax authorities, transfer pricing and withholding tax.

OECD Releases The 2025 Update To Its Model Treaty

The 2025 Update to the OECD Model Treaty has been released with changes being introduced to Article 25 on MAPs and its Commentary, as well as to the Commentaries on Article 5...

Netherlands Tax

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Loyens & Loeff

EU Tax Snippet Summer Series #4 EU ATAD 3 Directive – New York Office Snippet

As outlined in our earlier Snippet, the ATAD3 proposal was introduced to combat tax abuse by ‘shell companies' – EU holding and financing companies perceived to lack sufficient substance (𝐒𝐡𝐞𝐥𝐥𝐬).

Netherlands Tax

LL

Loyens & Loeff

European Commission Proposes Financial Contribution For EU Companies And Permanent Establishments

A financial contribution for EU companies has been included in the latest EU Own Resources proposal published by the European Commission on 16 July 2025.

European Union Tax

LL

Loyens & Loeff

Letter Secretary Of State On Lucrative Interest Scheme

On 1 July 2025, the Secretary of State for Finance submitted a letter to Parliament addressing alternative proposals regarding the current lucrative interest scheme (the "Letter").

Netherlands Tax

B

Buren

US Withdraws Support For Pillar II: Protective Measures Expected

Netherlands Tax

DB

De Brauw Blackstone Westbroek N.V.

EU Tax Directives #2: EU ATAD 3 Directive – New York Office Snippet

LL

Loyens & Loeff

Budget Day 2024: Changes To Payroll Taxes For Dutch Employers

Netherlands Tax

LL

Loyens & Loeff

Netherlands Enters Into Agreement With Singapore On The Application Of The Mutual Agreement Procedure Under The Multilateral Instrument

B

Buren

New Tax Treaty Between Spain And The Netherlands: Expected Impact On Spanish Real Estate Investments

European Union Tax

AM

Alvarez & Marsal

Advocate General Urges European Court Of Justice To Revisit Lexel Judgment In His Opinion Concerning Dutch Interest Deduction Limitation Rule

European Union Tax

LL

Loyens & Loeff

Shipping Update January 2024

Netherlands Transport

LL

Loyens & Loeff

Agreement Between Belgium And The Netherlands On Cross-Border Home Office Permanent Establishments

European Union Tax

LL

Loyens & Loeff

Een nieuw Belgisch-Nederlands belastingverdrag

LL

Loyens & Loeff

US MNEs, How Will Pillar Two Impact Your Business?

LL

Loyens & Loeff

Update On Dutch Implementation Of Pay Transparency Directive

Netherlands Employment

LL

Loyens & Loeff

[Blog] Ericsson et Lenovo : La fin de leur bataille autour des brevets 5G grâce à l'Arbitrage

European Union IP

NG

Novagraaf Group

Latest Developments On The EU Sustainability Omnibus

European Union Commercial

AO

A&O Shearman

[Blog] Innovation en Europe : des performances contrastées, la Chine en tête à l'échelle mondiale

European Union IP

NG

Novagraaf Group

European Commission Publishes Second Evaluation Of The Directive On Administrative Cooperation In Taxation (DAC)

Netherlands Tax

LL

Loyens & Loeff

European Commission Publishes A Legislative Proposal To Prevent The Misuse Of Shell Entities For Tax Purposes

On December 22, 2021 the European Commission published a legislative proposal to prevent the misuse of shell entities for tax purposes ("Proposal"). The Proposal is part of a wider ambitious agenda to combat tax avoidance and tax evasion.

European Union Tax

B

Buren

European Commission Publishes Far-Reaching Legislative Tax Proposals

On 22 December 2021, the European Commission released several legislative proposals that will impact corporate taxpayers.

European Union Tax

LL

Loyens & Loeff

Russian-Dutch Double Tax Treaty

On April 9, 2021 the Russian prime-minister signed Resolution #565 to approve the denunciation of the Russian-Dutch double tax treaty (DTT) and to submit the relevant draft federal law (Draft law) to ...

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Buren

Impuesto A Los Servicios Digitales: ¿un Mal Necesario?

Emine Constantin analiza los desafíos que la tecnología digital ha creado para el sistema tributario global y analiza cómo diferentes países están abordando esto a través de los impuestos...

Netherlands Tax

TG

TMF Group BV

Tax & Privacy Alert: OECD Model Reporting Rules Affecting Digital Platforms

Netherlands Tax

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Dentons

What You Need To Know About The Multilateral Instrument

Netherlands Tax

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Intertrust

Impact Of The Multilateral Instrument On Dutch Bilateral Tax Treaties

Netherlands Tax

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Dentons

Year-End Tax Bulletin 2019

Netherlands Tax

LL

Loyens & Loeff

OECD's Plans For Global Minimum Taxation: The Next Steps

Netherlands Tax

LL

Loyens & Loeff

Impact Of ECJ ‘Danish Cases' On Tax Treatment Of Holding Companies

Netherlands Tax

TG

TMF Group BV

Multilateral Convention Ratified By The Netherlands

Netherlands Tax

D

Dentons

How Are AIFMD And BEPS Impacting Economic Substance Needs For Fund Structures?

Worldwide Finance

TG

TMF Group BV

Dutch Supreme Court: No Dividend Tax On Basis Of Most Favored Nation Clause In Tax Treaty South Africa

Netherlands Tax

D

Dentons

¿Dónde debe establecer su entidad en la UE?

European Union Finance

TG

TMF Group BV

Multilateral Convention Ratified By The Netherlands

On March 5, 2019, the Upper House (Eerste Kamer) of the Dutch parliament approved the Multilateral Convention to implement tax treaty-related measures to combat base erosion and profit shifting.

Netherlands Tax

D

Dentons

How Are AIFMD And BEPS Impacting Economic Substance Needs For Fund Structures?

Gone are the days when having some office space or a couple of employees in a jurisdiction counted as economic substance for your fund structure.

Worldwide Finance

TG

TMF Group BV

Dutch Supreme Court: No Dividend Tax On Basis Of Most Favored Nation Clause In Tax Treaty South Africa

On January 18, 2019, the Dutch Supreme Court ruled in favor of a South African company that claimed a refund of 5 percent Dutch dividend withholding tax based on the most favored nation clause in the South Africa – Netherlands tax treaty.

Netherlands Tax

D

Dentons

¿Dónde debe establecer su entidad en la UE?

Descubra si estas jurisdicciones europeas clave son adecuadas para sus operaciones.

European Union Finance

TG

TMF Group BV

Keeping Up With A Rapidly Changing Tax World

Netherlands Tax

TG

TMF Group BV

European Commission Puts Netherlands On Notice Regarding Its Tax Treaty With Japan

The European Commission asked the Netherlands on 19 November to amend the limitation on benefits (LOB) provision in the existing Dutch-Japanese tax treaty.

Netherlands Tax

DB

De Brauw Blackstone Westbroek N.V.

OECD Releases Final BEPS Package

On 5 October 2015, the OECD published the final reports of the OECD/G20 Base Erosion and Profit Shifting project, which consist of a package of measures for a co-ordinated international approach to reform the international tax system.

LL

Loyens & Loeff

Benefits Of The New Netherlands And Curacao Tax Agreement

The tax arrangement has been closely monitored by TMF Group since its first publication in June 2014 and includes some of the recommendations of the OECD's BEPS project.

Netherlands Tax

TG

TMF Group BV

Luxembourg Bill Implements Anti-Abuse And Anti-Hybrid Rules For EU Intra-Group Dividends

Luxembourg recently published a bill to implement the new anti-hybrid rule and the general anti-abuse rule (GAAR) of the EU Parent Subsidiary Directive (PSD).

Netherlands Tax

DB

De Brauw Blackstone Westbroek N.V.

Beware: China – Netherlands Tax Treaty Has Impact On Income As Of 1 January 2015

Netherlands Tax

DB

De Brauw Blackstone Westbroek N.V.

Introduction Of New Reporting Requirements For Certain Intra-Group Lending, Licensing, And Leasing Activities

Netherlands Tax

JD

Jones Day

The Netherlands And US Agree On Automatic Exchange Of Tax Information

Netherlands Tax

DB

De Brauw Blackstone Westbroek N.V.

New Tax Treaty Between China And The Netherlands

Netherlands Commercial

DB

De Brauw Blackstone Westbroek N.V.

China Enters Into New Tax Treaty With The Netherlands

DB

De Brauw Blackstone Westbroek N.V.

A Dutch Tax Credit For Foreign Dividend W/H Tax, Even Though The Dividend Received Is Not Taxed In The Netherlands, Due To The Dutch Participation Exemption

Netherlands Tax

MH

Merlyn Holding BV

Worldwide Developments In The Tax Concept Of Substance

Netherlands Tax

MH

Merlyn Holding BV

Eurozone Exits: Dutch Legal And Tax Aspects

European Union Tax

DB

De Brauw Blackstone Westbroek N.V.

Independent Dutch Royalty Conduit Entities And Their Benefits For Multinational Enterprises

Netherlands Tax

MH

Merlyn Holding BV

The Use Of Dutch Legal Entities In International Tax Reduction Strategies, Part II

Netherlands Tax

MH

Merlyn Holding BV

The Use Of Dutch Hybrid Legal Entities In Group Structures Of Multinational Enterprises

Netherlands Tax

MH

Merlyn Holding BV

New Tax Treaty Between Japan And The Netherlands Approved By Dutch Parliament

Netherlands Tax

VT

VMW Taxand N.V.

Doing Business In Or Via The Netherlands: Changes To Dutch Tax Law As Of January 1, 2012

Netherlands Tax

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NautaDutilh

How To Deal With The LOB Provisions In New Tax Treaties?

Netherlands Tax

MH

Merlyn Holding BV

Recent Developments With The Dutch Dividend Withholding Tax – A Major Bottleneck In International Tax Planning

Netherlands Tax

MH

Merlyn Holding BV

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