The Finance Ministry of the Netherlands has announced the launch of a public consultation on the design of a new corporate tax group regime to replace the current fiscal unity regime. The consultation includes four possible approaches to resolve issues with the current regime:
Approach 1: Continue the current fiscal unity regime with the repair measures and, if necessary, introduce additional repair measures.
Approach 2: Completely abolish the fiscal unity regime without the introduction of a new tax group regime.
Approach 3: Introduce a loss or profit transfer regime in which each member of the tax group determines its own tax result, with the possibility of either offsetting loss/profit among group members or accounting for the total loss/profit in a single joint return.
Approach 4: Introduce a cross-border arrangement with object exemption for foreign corporate profits to bring the fiscal unity regime in line with EU law.
The consultation runs from 17 June 2019 to 29 July 2019, with a draft of the intended group regime proposal to be submitted to the House of Representatives in fall 2019.
