memento

Today, the Dutch government published updated decrees on Transfer Pricing (TP) and on the attribution of profits to a permanent establishment (PE).

Yesterday, the Dutch House of Representatives passed a bill to defer the moment employee stock options are taxed. Under the new rules, stock options are taxed when the underlying shares become tradable.

Recently, a District Court ruled on the application of art. 20a CIT Act in case of unrealized losses. The decision is relevant for M&A transactions involving a target company with unrealized losses.

On 20 May 2022, the Dutch Ministry of Finance published its Spring Memorandum (Voorjaarsnota) containing i.a. the following tax revenue-generating proposals for 2023.

On 11 May 2022, the European Commission published a proposal for a new Council Directive that aims to encourage businesses to attract equity funding instead of debt.

Today, the Dutch government published its plans for box 3, after the Dutch personal investment regime was found unlawful by the Dutch Supreme Court in the ‘Christmas ruling’.

Today, the Supreme Court ruled on the valuation of interest rate swaps related to floating interest loan payables.

The Dutch government launched a consultation bill to implement the EU Directive on cross-border conversions, mergers and divisions in Dutch law.

The OECD published a consultation on Pillar 1’s Amount A. Amount A defines income to be attributed to market jurisdictions. A consultation on Amount B (remunerating sales&marketing activities) is expected mid-2022.

The bill on the change in entity classification rules for [...]