The Deputy Minister of Finance, in a November 2018 memorandum, answered questions raised by the Lower House about pending fiscal unity emergency repair legislation.
The bill (Wet spoedreparatie fiscale eenheid) was presented to the Lower House in June 2018. The emergency repair measures mean that, for a number of legal provisions, the approach to be taken is as if a fiscal unity for corporate income tax purposes does not exist.
The Deputy Minister of Finance’s memorandum addresses, among other items, the effective date, the interest deduction limitation to avoid profit shifting, the subject-to-tax test for a participation exemption, the interest deduction limitation for excessive participation interests, and the loss set-off in the case of a change of control.
Read a November 2018 report prepared by the KPMG member firm in the Netherlands
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