OECD updates MLI arbitration profiles for Australia, Japan, and the Netherlands
The OECD has published updated arbitration profiles for the Netherlands, Australia, and Japan under the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting (MLI). Part VI of the MLI allows
See MoreNetherlands unveils 2027 tax plan with corporate, VAT and PIT changes
The Dutch government presented the 2027 Budget, including the Tax Plan for 2027 (Belastingplan 2027), on 15 September 2026. Corporate adjustments From 2027, embedded currency hedging results on participation investments will no longer qualify
See MoreNetherlands sets 2030 deadline for mandatory domestic e-invoicing
The Netherlands government has issued Letter No. 2026-0000288216 of 11 September 2026, detailing the strategic implementation framework for electronic invoicing (e-invoicing) and digital reporting in the Netherlands. This policy transposes Council
See MoreNetherlands: MoF opens consultation on service taxation rules for developing countries
The Netherlands Ministry of Finance has initiated a public consultation on changes to how the Netherlands will handle taxation of service income in future tax treaties. The consultation runs from 9 September 2026 to 23 October 2026 and invites
See MoreNetherlands updates Box 3 tax decree to incorporate rebuttal scheme
The Netherlands has issued Decree No. 2026-2613 of 4 September 2026, which replaces the previous Decree No. 2024-5944 of 7 May 2024 concerning income from savings, debts, and investments under Box 3. The updated decree incorporates the
See MoreNetherlands updates tax treaty interpretation rules in new decree
The Netherlands State Secretary for Finance has issued the Decree nr. 2026-15551, updating and clarifying several key tax treaty interpretations on 6 August 2026. The Decree No. 2026-15551, which replaces Decree No. 2023-11648 of 16 June 2023,
See MoreNetherlands limits split-up tax deferrals, explicitly excludes anti-abuse protections
The Netherlands has published Decree No. 2026-262957 of 6 August 2026 (demergers) from the State Secretary for Finance on pure demergers on 18 August 2026. The Decree No. 2026-262957 of 6 August 2026 outlines the Dutch tax policy regarding pure
See MoreNetherlands tax authority updates legal merger framework for 2026
The Netherlands published Decree No. 2026-262956 of 6 August 2026, issued by the State Secretary for Finance, setting out tax-neutral restructuring relief for qualifying legal mergers. The decree outlines the updated 2026 regulatory framework for
See MoreNetherlands: Tax Authorities clarify Pillar Two Minimum Tax Act 2024
The Dutch Tax Authorities have updated their Questions and Answers (Q&A) on the Minimum Tax Act 2024 (MTA 2024), providing revised guidance on the application of the legislation, including the treatment of penalties, tax interest, appeal periods
See MoreNetherlands amends tax penalty rules to support Pillar Two, DAC8, DAC9 rollout
The Netherlands has gazetted Decision No. 2026-14582 of 30 July 2026 on 7 August 2026, bringing amendments to the Decree on Administrative Fines of the Tax and Customs Administration (BBBB). These changes primarily adapt the administrative penalty
See MoreNetherlands updates hybrid mismatch guidance with new rules on US tax regimes, permanent establishments
The Netherlands published the Hybrid Mismatch Policy Decision 2026 (Decree No. 2026-12123), issued by the State Secretary of Finance on 24 July 2026, replacing the previous policy decision that was originally issued in 2021 and subsequently updated
See MoreNetherlands sets escalating fines for trust UBO registration failures
The Netherlands Ministry of Finance has published a policy rule on 13 July 2026 outlining new administrative fine policies regarding the registration of ultimate beneficial owners (UBOs) for trusts and similar legal arrangements. Effective from 1
See MoreNetherlands: CFC levy cannot offset low-tax free investments under participation exemption
The Dutch Tax Administration issued a clarification on 21 July 2026, explaining that the controlled foreign company (CFC) levy does not take low-tax-free investments into account. The recent clarification by the Dutch Tax Administration provides
See MoreNetherlands consults bill targeting compliance simplifications, adjustment of reorganisation facilities, hybrid entity changes
The Dutch government has put forward a comprehensive legislative package designed to refine the Income Tax Act 2001, the Corporate Income Tax Act 1969, the Successions Act 1956, and other tax frameworks. Following this, the government has opened a
See MoreNetherlands consults sugar tax reforms, proposes tiered levy on beverages and food products by 2030
The Netherlands Ministry of Finance has launched a public consultation on proposed sugar tax reforms on 16 July 2026. The proposals would replace the current flat-rate excise tax on non-alcoholic beverages with a tiered sugar-based tax and
See MoreNetherlands, Finland establish arbitration procedures under BEPS MLI tax treaty framework
The Netherlands has gazetted a Memorandum of Understanding (MoU) with Finland establishing the procedures for applying the arbitration provisions set out in Part VI of the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent
See MoreNetherlands, Sweden sign new tax treaty
The Netherlands government has announced that it has signed a new income tax treaty with Sweden on 24 June 2026. This new tax treaty replaces the 1991 agreement between the two countries to align with both countries' current tax policy
See MoreNetherlands: Exit payments from departing cooperative members are taxable profit
The Netherlands Tax Administration’s Knowledge Group, responsible for specific corporate tax profit determination, has issued a position outlining the corporate income tax treatment of exit payments received by a cooperative from members who
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