Netherlands 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
See MoreNetherlands announces business incentives, lower property taxes in 2027 tax plan provisional measuresÂ
The Dutch State Secretary for Finance has informed Parliament, via a letter, of a provisional outline of measures expected to be included in the 2027 Tax Plan package on 10 June 2026. The complete package is scheduled to be presented on
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Netherlands, Peru sign customs mutual assistance agreement
Peru’s Ministry of Foreign Affairs has announced that officials from the Netherlands and Peru signed an Agreement on Mutual Administrative Assistance in Customs Matters on 4 June 2026. The agreement will facilitate the exchange of information
See MoreBenin, Netherlands sign income tax treaty
Benin and the Netherlands signed an income tax agreement in Cotonou on 21 May 2026. The agreement is aimed at preventing double taxation while strengthening measures against tax avoidance and evasion. The treaty aligns with current OECD/G20 Base
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Countries move into Pillar Two filing phase as first compliance deadlines approach
Tax authorities across several jurisdictions are accelerating the rollout of compliance systems for the OECD’s Pillar Two global minimum tax regime, with new filing portals, technical specifications, deferrals and reporting procedures now being
See MoreNetherlands: Omnibus tax bill clarifies treatment of qualifying domestic top-up taxes for participation credit
The Netherlands government has submitted the Omnibus Tax Bill (Fiscale Verzamelwet 2027) to parliament for approval. The Bill, together with its explanatory memorandum, was published on 29 April 2026. It sets out the legislative progress of the
See MoreNetherlands to launch digital platform for Pillar Two tax submissions in June 2026
The Dutch Tax and Customs Administration has announced that digital services for Pillar Two global minimum tax filings will go live from 1 June 2026, targeting large multinational enterprises. The Netherlands' Minimum Tax Act 2024, effective from
See MoreNetherlands: MoF announces 2026 tax treaty agenda, possible review of Panama agreement
The Netherlands Ministry of Finance has issued a letter to the House of Representatives outlining planned and ongoing negotiations on tax treaties in 2026 on 23 April 2026. A separate government release indicates that the Netherlands is currently
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Netherlands updates list of developing countries for tax treaty purposes in 2025
The Dutch Tax Authority has published its annual list of countries designated as developing nations under Article 6 of the 2001 Double Taxation Prevention Decree (Bvdb 2001) for 2025. Since 1 January 2017, the Netherlands has applied specific
See MoreNetherlands consults stricter anti-dividend stripping rules with 15% net return test
The Dutch Ministry of Finance has initiated a public consultation regarding additional measures to prevent dividend stripping on 16 April 2026. Dividend stripping is a method by which individuals or companies attempt to pay less or no tax on
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Netherlands clarifies permanent establishments, joint ventures, residency rules under Pillar Two
The Dutch Tax Authority’s Pillar Two Knowledge Group has issued a series of positions on the application of the Minimum Tax Act 2024. These guidelines provide clarification on how the Act should be applied in relation to various specific issues
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