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...
This question - which is of utmost importance as the OECD commentaries provide key insights to tax authorities, taxpayers and judges, on...
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...
For the first time, the Dutch Supreme Court has denied the benefit of the EU Parent-Subsidiary Directive based on the existence of a...
Multinationals based in the Netherlands should prepare for an increase in their Dutch tax burden. A number of measures, including changes...
Political developments are hard to predict. The case of the Dutch dividend withholding tax is a prime example of how quickly the...
As the 31 December 2019 deadline for the implementation of DAC6 into the national legislation of EU Member States draws closer,...
The Dutch government has released its budget plans for 2020, as well as certain tax proposals. The introduction of a withholding tax on...