The 2021 Dutch tax package was presented, together with certain other tax measures, on September 15. Highlights of particular relevance to multinationals include modifications to the corporate income tax (CIT) rate, clarifications of the interest deduction limitation rules, a restriction in the liquidation loss regime, and the announcement of a wage tax discount for investments in the Netherlands. In addition, the legislature proposed changing the loss utilization rules effective January 1, 2022 and expects to propose additional legislation in 2021 intended to better align the treatment of a fiscal correction based on the arm’s-length principle. The 2021 tax proposals are currently being discussed in parliament and are expected to be approved by the Senate in early December. During this process some small amendments may be made to the proposals, but no major changes are expected at this stage.
Multinational entities should pay particular attention to the following provisions within the proposal: