The Dutch government, on September 17, 2019 (budget day), presented the Dutch tax package, which contains tax measures that begin in 2020. The proposed measures, which include rules regarding conditional withholding tax on interest and royalties paid to affiliated entities in low-tax jurisdictions, will enter into force January 1, 2021. The package also contains amendments to the existing anti-abuse provisions in the Corporate Income Tax Act and Dividend Withholding Tax Act as a result of the Court of Justice of the European Union (CJEU)’s Danish beneficial ownership cases. The amendments are proposed to enter into force on January 1, 2020.
The Dutch government plans to discuss the tax package in the fall of this year.
Taxpayers should determine whether they meet the new standards of the amended anti-abuse rules included in the Dutch Corporate Income Tax Act and Dividend Withholding Tax Act.