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Within the Netherlands, there are various anti-abuse or anti-avoidance rules containing purpose tests. Most relevant within the context...
In the Netherlands, the term beneficial owner can arguably have two different meanings: a domestic law meaning and a tax treaty law...
In a previous post, Maarten van der Weijden indicated that a decision by the Amsterdam Court of Appeal on 22 December 2020 set the stage...
The decision of the European Court of Justice in the Lexel AB case raises questions whether the valid business reason exception of...
The Amsterdam Appeal Court decision which addresses this question deals with the double tax treaty between France and the Netherlands of...
On 4 March 2021, the Dutch government presented a draft bill for comments by interested parties introducing fundamental changes to Dutch...
Recently, the highest court in the Netherlands ruled that (a) uncovered call options cannot be regarded as a participation, and (b)...
The Dutch Supreme Court decided in the Köln Aktienfonds Deka (KA DEKA) case that foreign investment funds are eligible for a refund of...
This is the last blog in a series on three documents published around the 2021 Dutch budget. It deals with a letter from the Dutch...
Following my blog on the (non-)amendment of the Dutch participation exemption for substance-less holding companies, this blog considers...
Somewhat hidden among the massive volume of tax legislation that came out as part of the 2021 Dutch budget on 15 September 2020, three...
The Dutch government published its 2021 budget on 15 September 2020. The tax measures were largely as anticipated and, where corporate...
Tax authorities in Europe are racing to apply the principles set forth by the European Court of Justice in the Danish conduit cases to...
The paragraph of the OECD transfer pricing guidance on financial transactions dealing with parent guarantees is, in my view, incompatible...
As countries ramp up social distancing measures to combat COVID-19, the economic costs of the virus spiral and the G7 leaders have called...
The Dutch Supreme Court’s assessment whether the shareholder and distribution requirements for fiscal investment institutions (FII) in...