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Netherlands: Tax plan update, “emergency repair” of fiscal unity rule

Netherlands: Tax plan update

The Deputy Minister of Finance on 25 October 2018 published answers to questions raised by the Lower House about legislative proposals in the 2019 Tax Plan package (including ATAD1).


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Several “Memoranda of Amendment” were also sent to the Lower House, and on 26 October 2018, the Memoranda of Amendment resulting from the government’s reconsideration of the business climate package were also published. These include:

  • Further reduction of the corporate income tax rate and no additional increase of the tax rate for a substantial interest
  • No repeal of the dividend withholding tax
  • No introduction of a conditional withholding tax on dividends
  • Reversal of the amendments to the fiscal investment institution (fiscale beleggingsinstellingen—FBI) regime
  • Transition rules for limiting, for corporate income tax purposes, the depreciation of property for a taxpayer’s own use
  • Transitional rules for the “30% ruling” (tax relief for certain employees working in the Netherlands, recruited from abroad and possessing expertise not present or scarce in the Dutch labor market)
  • Amendment of the emergency repair of the fiscal unity
  • Current account measure for director-major shareholders


Read an October 2018 report prepared by the KPMG member firm in the Netherlands

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