2019 Tax Package - The Netherlands
Global Tax Update:September 2018/Netherlands
Today, the government’s budget plans for the coming year were released in public. The budget plans contain the details of the Tax Package 2019.
The Tax Package 2019 contains several important amendments and plans for the Dutch corporate tax and Dutch (dividend) withholding tax acts, mostly driven by the desire to improve the Dutch business climate, for instance by reducing the corporate tax rate and abolishing the dividend withholding tax. At the same time, tax avoidance is combatted through several legislative anti-abuse measures.
Below you will find a summary of the most notable items in the Tax Package 2019 that are relevant for Dutch subsidiaries of Japanese MNC’s.
1. Corporate income tax
(1) Corporate income tax rate and loss compensation rules
(2) Interest deduction limitation rules
(3) Introduction of Controlled Foreign Company (“CFC”) rules
2. (Dividend) withholding tax
(1) General information
(2) Definition of low rate (or non-cooperative) country and other abusive situations
(3) Related Entities
(4) Method of levying the WHT
(5) WHT rate
3. 30% facility
* This Article is based on the relevant Japanese or specific country’s tax law and other authorities in effect on the date of this Article. This Article would not be guaranteed updating if there are any changes in Japanese tax law, any other law, or interpretations by the courts or tax authorities thereof after the date of this Article.