The Netherlands has published the Minimum Tax Implementation Decree 2024 in the Official Gazette No. 2024/442, on 23 December 2024, which contains rules for implementing the Minimum Tax Act 2024.
The Decree also outlines guidelines for implementing OECD Pillar Two, including the 15% minimum tax rate for multinational enterprises (MNEs). The rules provide explanations on determining qualifying income or losses, calculating adjusted taxes, and establishing transition provisions.
The decree went into effect on 31 December 2024 and applies retroactively from 31 December 2023.
Earlier, the Netherlands passed the Tax Plan for 2024 on 19 December 2023.