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Following our newsletter on the extension of the Dutch dividend withholding exemption to all treaty countries (click here), the Dutch State secretary of Finance has now published the declaration that needs to be filed with the Dutch tax authorities when applying…

Als vervolg op onze nieuwsbrief over de verruiming van de Nederlandse inhoudingsvrijstelling op deelnemingsdividenden naar alle verdragslanden (klik hier), heeft de Staatssecretaris van Financiën vorige week de nieuwe opgaaf dividendbelasting gepubliceerd. Indien de inhoudingsvrijstelling wordt toegepast moet de belastingdienst hierover worden…

On November 2, the House Republican's tax reform bill – the Tax Cuts and Jobs Act – was released. This bill is 429 pages and should provide for extensive tax reform. The bill would immediately reduce the statutory tax rate to 20% and move to a territorial system of taxing foreign profits with anti-base erosion provisions for both US-based and foreign-based multinational companies. A new excise tax of 20% will be introduced on deductible payments from US companies to related foreign companies that in fact acts similar to the border adjustment in the House Republican Blueprint, but only for outbound payments. A brief summary of the other key provisions is provided below. President Trump intends to sign the bill before the Thanksgiving holiday, but there are several unpopular provisions that will potentially get push-back and changes are likely to be made. Given the current political US landscape and the unprecedented situation, the last major US tax reform took place in 1986, this seems an optimistic outlook. Of course we will keep you posted on updates following the legislative process.

Introduction According to Dutch transfer pricing legislation (article 8b of the Dutch Corporate Income Tax Act), Dutch tax payers need to have documentation available that demonstrates the arm’s-length nature of transfer prices applied to intra-group transactions. This transfer pricing documentation…

Martha Formenti (member of our Brazilian Desk) has been appointed as a Brazil’s National Branch Reporter on the topic “Withholding tax in the era of BEPS, CIVs and digital economy” for the IFA Congress in Seoul in 2018. Martha is…

In the framework of the expected corporate income tax reform (further to the agreement reached at government level last summer), the Belgian government intends increasing the participation exemption (dividend received deduction), which under current legislation is limited to 95% of…

On 25 October 2017, Advocate General (AG) Campos Sánchez-Bordona issued his opinion in the Joined Cases C‐398/16 and C‐399/16 X BV & X NV versus the Dutch State Secretary of the ministry of finance (Staatssecretaris van Financiën). These cases were…

This afternoon Prime Minister Mark Rutte released the highlights of the new government (Rutte III). As far as taxation is concerned the most important changes are:

On 29 September 2017, during the Tallinn Digital Summit, the EU Council of Economy and Finance Ministers (Ecofin) discussed the supposedly insufficient taxation of companies active in the “digital economy”. In preparation to this meeting the European Commission (Commission) published…

We are happy to announce that T/A economics is mentioned as ‘firm to watch’ in the World Transfer Pricing 2018 rankings for all three Benelux countries. The rankings are brought by TPWeek, an online weekly newsletter dedicated to transfer pricing. Consult the…

Op 22 september 2017 heeft de Hoge Raad geoordeeld over het al dan niet toekennen van een step-up bij remigratie van een houder van aanmerkelijk belang in een Nederlandse vennootschap.

On the third Tuesday of September 2017 (traditionally Budget Day in the Netherlands), the Ministry of Finance has proposed changes to the Dutch Dividend Withholding Tax Act and the foreign taxpayer rules in the Corporate Income Tax Act (“CITA”). For…