09/May/2023

NL Tax Alert: Tax agenda published

Today, the Dutch government published its tax agenda with the following relevant news items:

The CV and FGR transparency changes will be delayed to 2025, with transitional rules for 2024. Amongst others, the Open CV will be abolished.
For financing/licensing/leasing companies with limited risks, the safe habor rule equity might be abolished. An open norm for determining an appropriate equity would replace the current EUR 2m/1% rule. More news is expected before the summer.
The ATAD3/Unshell directive is (still) in negotiation.
Dividend stripping rule changes to be announced in September, a.o. introducing a legislative registration date and changing the burden of proof.
A Pillar 2 legislative proposal is expected before the summer.

The tax agenda repeats the measures relevant for the real estate industry, as published last week (see previous news item).