Subjects:

Taxation

Contents:

Contents Include

An introduction to Dutch domestic law, including both corporate and personal income tax, dividend withholding tax, capital duty, real estate transfer tax.

An in-depth analysis of the Dutch corporate income tax system including financing a taxpayer, tax consolidation, holding companies and participation exemption, corporate reorganizations, financing companies, transfer pricing, loss compensation, inbound investments and anti-abuse legislation.

Recent changes to Dutch participation exemption, abolishment of capital duty, abolishment of hybrid loan legislation, changes to Dutch interest limitation rules are highlighted.

An overview of Dutch international law examining treaties, the tax agreement for the Kingdom of the Netherlands, the unilateral decree for the prevention of double taxation and EU law.

A description of Dutch dividend tax including EU entities and dividend tax credit.

An overview of the exchange of information including national law, the ruling practice, treaties and EU law.

A description of the personal income tax, including 30% cost allowance and employee stock option plans.

This second edition of The Netherlands in International Tax Planning has been necessitated by the substantial amendments introduced to the Dutch corporate income tax system per 1 January 2007. These changes include a considerable revision of the participation exemption and several changes to Dutch interest limitation rules.

In addition, a 10% royalty income box has been introduced and a 5% interest income box proposed; the interest income box still needs the blessing of the European Union. Dutch capital duty was already abolished per 1 January 2006. This book discusses current law only.

Similar to the first edition, the book provides a practical guide on dealing with the Dutch taxation of businesses investing into, via (conduit structures), or from the Netherlands. The book focuses on corporate income tax and dividend tax as well as on other issues typical of an international environment. Where relevant, the link between Dutch law and European law on direct taxation is also mentioned. Several examples of practical structures and calculations are given in order to enhance the reader’s understanding.

The second edition of The Netherlands in International Tax Planning is an indispensable tool for corporate foreign investors, international tax practitioners, tax advisers and lawyers involved in cross-border transactions to or from the Netherlands. It is a valuable reference work for academics and all those interested in gaining a better understanding of the Dutch tax legislation.