The Netherlands published the legislative proposal ‘Minimum Tax Act 2024 (Pillar Two)’ in May 2023. Position of the Netherlands on the Organisation for Economic Co-operation and Development's (OECD’s) Pillars One and Two Finally, a legislative initiative is currently pending that aims to prevent the avoidance of dividend WHT by emigrating or cross-border merging of large companies with foreign entities ( see Conditional dividend exit tax on relocation of head offices - proposal below). As of 2024, this WHT will also apply to dividends. As of 2021, a withholding tax (WHT) on interest and royalties is due in certain situations, namely where the recipient is based in a low-tax jurisdiction or a non-cooperating jurisdiction in respect of information exchange, or in cases of abuse ( see Conditional WHT on interest and royalty payments in the Withholding taxes section). for patent income, investment vehicles, and income from ocean shipping activities). The corporate tax system of the Netherlands contains a number of well-known features providing for an attractive investment climate, such as: the fiscal unity regime with tax consolidation for group companies, a full participation exemption for capital gains and dividends from qualifying participations, and several favourable tax regimes (e.g.
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