Netherlands: Tax Treaties

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Article
Recent Tax Developments For Dutch Pension Funds
The EU's Taxation Omnibus proposal aims to expand the Parent-Subsidiary Directive to include pension funds and eliminate minimum ownership thresholds, potentially removing significant tax obstacles for cross-border EU investments. Meanwhile, the Netherlands has introduced temporary relief measures for collective investment vehicles (FBIs) affected by recent tax classification reforms, providing a pragmatic solution for pension funds navigating new transparency requirements.
Netherlands Tax
LL
Loyens & Loeff
Article
Dutch Ministry Of Finance Updates Hybrid Mismatch Decree: Broader Guidance And New Practical Examples
The Dutch Ministry of Finance has issued an updated Decree providing crucial clarifications on the practical application of hybrid mismatch rules under ATAD2. These updates address key interpretative questions that have emerged in practice, particularly concerning the interaction with US tax regimes, capitalised acquisition costs, and cost-plus transfer pricing structures.
Netherlands Tax
LL
Loyens & Loeff
Article
European Commission Adopts Tax Simplification Package To Boost EU Tax Competitiveness, Reduce Administrative Burdens
The European Commission's Tax Simplification Package proposes sweeping reforms to EU direct tax directives, promising to cut business compliance costs by EUR 8 billion annually. The draft Omnibus Directive would eliminate minimum holding requirements for withholding tax relief, ease interest deduction limitations, and introduce an EU-wide R&D allowance. With negotiations targeting conclusion in Q4 2027 and implementation by 2029, these changes could fundamentally reshape cross-border taxation for companies
Worldwide Tax
GT
Greenberg Traurig, LLP
Article
European Commission Proposal For A Recast Of The Directive On Administrative Cooperation
The European Commission has proposed a comprehensive recast of the Directive on Administrative Cooperation, consolidating DAC1 through DAC9 into a single legal framework. This legislative initiative aims to streamline and strengthen the EU's administrative cooperation mechanisms in direct taxation, with significant implications for compliance frameworks across member states.
European Union Tax
LL
Loyens & Loeff
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