The Dutch House of Representatives approved a budget proposal on 11 November which included an approval vote on the government’s tax proposals for 2022 and beyond – some of which are relevant for multinational corporations.
The documents include a proposal to implement the reverse hybrid mismatch rules from the EU’s Anti-Tax Avoidance Directive II (ATAD – in force from 1 January 2022).
In brief:
- The government has voted to increase the upper bracket corporate tax rate from 25% to 25.8%
- Interest deductibility under the EBITDA rule (introduced as part of EU Anti-Tax Avoidance Directive I) has decreased from 30% to 20% of the taxpayer’s EBITDA (earnings before interest, taxes, depreciation and amortisation).
- Unilateral downward transfer pricing adjustments are now limited in cases where there is no corresponding taxable adjustment.
The proposals are yet to pass the Senate but, as the Dutch Senate cannot amend legislative proposals, they are seen as final. The Senate is expected to vote in mid-December.
If you’d like more information or help with your Netherlands tax compliance, simply get in touch.
Local Knowledge – International Coverage
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