2018 Tax Package - The Netherlands
Global Tax Update:September 2017/Netherlands
On 19 September 2017, the government's budget plans for the coming year were released in public. The budget plans contain the details of the Tax Package 2018. (Global Tax Update:September 2017/Netherlands)
The Tax Package 2018 contains some important amendments to Dutch tax law which are relevant for Dutch subsidiaries of Japanese MNC’s.
This newsletter introduces a summary of the most notable items in the Tax Package 2018.
1. The Netherlands extends the scope of the Dutch dividend withholding tax act exemptions
Exemptions in Dutch dividend withholding tax
Under current law, Dutch BVs/NVs are in principle required to withhold a 15% tax on dividends paid to shareholders. However, dividends distributed by a Dutch cooperative, in principle, are not subject to Dutch dividend withholding tax, except in certain situations where abuse of law is present.
1) Anti-abuse rule
2) Holding cooperatives
3) Effective date and formalities
2. Other proposed legislation
As of 1 January 2016, a Dutch taxpayer that meets the Country-by-Country Report (“CbCR”) requirements, needs to prepare and file a CbCR with the Dutch Tax Authorities in cases when the Ultimate Parent Company of the Group (“UPC”) is not (yet) obliged to file a CbCR in its own resident state.