The Dutch government has presented the tax plan for 2018 on 19^th September 2017. If adopted, these proposals will be entered into force on 1^st January 2018. 2018 tax plan contains various other amendments on a variety of topic and these are given below:

• New dividend levy tax liability for Dutch “holding cooperatives”;
• Tightening of the conditions for the discounting of interest on intra-group liabilities financed by connected loans from third parties;
• Extension of the full exemption from dividends;
• Change in the scope of non-resident corporation tax arrangements for major investments in Dutch companies.

New dividend withholding tax obligations for holding Cooperatives

• It is proposed to amend the dividend withholding tax act by broadening the withholding tax exemption and by subjecting holding cooperatives to dividend withholding tax. This exemption only applies if a tax treaty with a dividend clause has been concluded with the Netherlands and the recipient qualifies for treaty benefits.
• Holding cooperatives are qualified as such if their activities usually consist for 70% or more of owning shareholdings that qualify for the participation exemption (directly or indirectly) loans to affiliated companies or persons.
• There must be a profit distribution to a “qualifying membership right” (i.e. membership rights that grant an entitlement to at least 5% of the annual profit or to at least 5% of the liquidation dividends).

Non-holding or “real” cooperatives are not subject to dividend tax.

Country-by-country reporting:

As per 2016, the Netherlands implemented country-by-country reporting, Dutch resident taxpayers part of a multinational with a turnover exceeding EUR 750 million, need to prepare this report. In principle, a country-by-country report should be submitted in the jurisdiction of the ultimate parent entity.