Netherlands: Earnings stripping, ATAD1, fiscal unity | KPMG Global
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Netherlands: Update on earnings stripping, ATAD1, fiscal unity proposals

Netherlands: Earnings stripping, ATAD1, fiscal unity

The Deputy Minister of Finance in May 2018 sent letters to both houses of parliament in response to questions and to explain the plans for legislation to implement an anti-tax avoidance directive (ATAD1) and the fiscal unity rules for corporate income tax purposes.


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According to the Deputy Minister, the government has decided that legislation for earnings stripping rules would:

  • Provide no group exemption
  • Find “grandfathering” of loans already in place in June 2016 to be undesirable, but that there may be sufficient opportunity for further discuss as to provide for grandfathering—the government's aim to reduce the corporate income tax rate also may imply that if transitional rules are put in place, they could be financed by a (temporary) more modest reduction of the corporate income tax rate
  • Provide a €1 million threshold


Read a May 2018 report prepared by the KPMG member firm in the Netherlands

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