The OECD released a report titled: “Revised BEPS Action 5 Transparency Framework on Tax Rulings”
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On September 8, 2025, three days later than initially announced, The OECD released a report titled: “Revised BEPS Action 5 Transparency Framework on Tax Rulings”.
The Dutch cabinet is looking into additional measures to tackle dividend stripping
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On June 27, 2025 the Dutch Secretary of State for Finances sent a letter to the Dutch Parliament. As of January 1, 2024, a number of measures to strengthen the approach to combating dividend stripping have come into effect in the Netherlands. In addition, the previous Dutch cabinet announced further research into possible additional measures against dividend stripping. With this letter, the Secretary of State provides the Parliament with a status update regarding this research and outlines the next steps.
The Canadian Government rescinds its digital services tax
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On June 29, 2025 the Canadian Department of Finance released a press release in which it announced that the Canadian Government rescinds its digital services tax to advance broader trade negotiations with the United States.
G7 statement on global minimum taxes / Pillar 2
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On June 28, 2025 a G7 statement on global minimum taxes was issued.
The Court of Appeal of The Hague ruled in 3 similar cases on the relevance of the outcome of a Mutual Agreement Procedure for earlier years
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On May 28, 2025 on the website of the Dutch Courts 3 judgments of the Court of Appeal of The Hague on the relevance of the outcome of a Mutual Agreement Procedure for earlier years. The judgments regard the question whether for the financial years 2018 through 2020 under the Dutch-Brazilian DTA the tax sparing credit of Article 23, Paragraph 4, section a (a tax sparing credit of 25% applying to dividends as meant in Paragraph 2 of Article 10 of the Convention) or the tax sparing credit of Article 23, Paragraph 4, section b (a tax sparing credit of 20% applying to interest as meant in paragraph 2 of Article 11) applies to income that qualifies as juros sobre o capital próprio (Hereinafter: JCP) under Brazilian law? A JCP in the English Language is referred to as “Interest on Net Equity” (Hereinafter: IoNE) or as an “Allowance for corporate equity”.
The opinion of the Advocate General in Case C‑321/24, Attal and Associés (Free movement of capital – Declaration of succession – Calculation of notary’s remuneration)
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On May 22, 2025 on the website of the Court of Justice of the European Union (CJEU) the opinion of Advocate General Campos Sánchez-Bordona in Case C‑321/24, BC versus SCP Attal et Associés, ECLI:EU:C:2025:376, was published.
Position of the Dutch tax authorities on the application of the withholding exemption of the Dutch dividend withholding tax Act in cases the dividend is not eligible for treaty benefits
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On May 13, 2025 on the website of the Dutch tax authorities a very interesting, and, at least for us, an also surprising, position paper of the Knowledge Group dividend withholding tax and withholding taxes of the Dutch tax authorities was published (KG:024:2025:4). In this position paper the Knowledge Group has answered a question about the application of the withholding exemption under Article 4, Paragraph 2, of the Dutch Dividend Withholding Tax (Hereinafter: the DDWT) Act in the event that a dividend is distributed and that dividend is not eligible for treaty benefits.
The Inclusive Framework on BEPS released a consolidated version of the Commentary to the Global Anti-Base Erosion Model Rules
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On May 9, 2025 the OECD released a consolidated version of the Commentary to the Global Anti-Base Erosion Model Rules.
Memorandum of Understanding as concluded by the Dutch and German Ministries of Finance on their intend to continue their discussion on the tax consequence of teleworking by cross-border workers
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In the Dutch State Gazette of May 9, 2025 a Memorandum of Understanding as concluded by the Dutch and German Ministries of Finance that was issued on the occasion of the signing of the Protocol amending the Convention of April 12, 2012 between the Federal Republic of Germany and the Kingdom of the Netherlands for the avoidance of double taxation and the prevention of tax evasion with respect to taxes on income as amended by the Protocol of January 11, 2016 and the Protocol of March 24 2021, on April 14, 2025 was published.
The DAC9 Directive has been published in the Official Journal of the European Union
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Council Directive (EU) 2025/872 of 14 April 2025 amending Directive 2011/16/EU on administrative cooperation in the field of taxation (DAC 9) has been published in the Official Journal of the European Union of May 6, 2025. The Directive will enter into force on May 7, 2025. Consequently Member States will have to adopt and publish by December 31, 2025 the laws, regulations and administrative provisions necessary to comply with this directive. The first top-up tax reporting is due by June 30, 2026. Countries opting to delay the implementation of the Pillar 2 Directive are still required to transpose DAC 9 by the same deadline.
Protocol amending the existing DTA as concluded between the Kingdom of the Netherlands and the Federal Republic of Germany has been published in the Dutch State Gazette
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A Protocol amending the existing Convention between the Kingdom of the Netherlands and the Federal Republic of Germany for the avoidance of double taxation and the prevention of tax evasion with respect to taxes on income as concluded in Berlin on April 12, 2012 as amended by the Protocol of March of 24, 2021 has been published in the Dutch Treaty Gazette of May 1, 2025. The text of the Protocol was published in both the Dutch and the German language.
Competent authority mutual agreement on the implementation of part VI of the multilateral convention to implement tax treaty related measures to prevent BEPS as concluded between the competent authorities of Belgium and The Netherlands
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The competent authority mutual agreement on the implementation of part VI of the multilateral convention to implement tax treaty related measures to prevent base erosion and profit shifting as concluded between the Competent Authority of the Kingdom of Belgium and the Competent Authority of the Kingdom of the Netherlands was published in the Dutch State Gazette of April 17, 2025.
The Council of the European Union adopted the DAC9 Directive
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On April 14, 2025 the Council of the European Union (Hereinafter: the Council) adopted the DAC9 Directive. The adopted Directive further amendments Directive 2011/16/EU on administrative cooperation in the field of taxation. The objective of the DAC9 directive is to put into operation specific provisions of the Pillar 2 Directive (Council Directive (EU) 2022/2523 of December 15, 2022) that implemented in the EU the G20/OECD global agreement on international tax reform.
The CJEU ruled in Case C-228/24, Nordcurrent group (The anti-abuse provision of the Parent-Subsidiary Directive)
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On April 3, 2025 on the website of the Court of Justice of the European Union (CJEU) the judgment of the CJEU in Case C-228/24, ‘Nordcurrent group’ UAB Valstybinė mokesčių inspekcija prie Lietuvos Respublikos finansų ministerijos, ECLI:EU:C:2025:239, was published.
The opinion of the Advocate General in the joined Cases C‑92/24 to C‑94/24, Banca Mediolanum, Banca Mediolanum – II and Banca Mediolanum – III (The interpretation of Article 4 of the Parent Subsidiary Directive)
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On March 27, 2025 on the website of the Court of Justice of the European Union (CJEU) the opinion of Advocate General Kokott in the joined Cases C‑92/24 to C‑94/24, Banca Mediolanum SpA and Others versus Agenzia delle Entrate – Direzione Regionale della Lombardia, ECLI:EU:C:2025:223, was published.
The CJEU ruled in Case C-135/24, John Cockerill (The interpretation of Article 1, Paragraph 4 and Article 4 of the parent-subsidiary directive)
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On March 13, 2025 on the website of the Court of Justice of the European Union (CJEU) the judgment of the CJEU in Case C-135/24, John Cockerill SA versus État belge (the Belgian State), ECLI:EU:C:2025:176, was published.
The European Commission calls on Spain to allow for a deduction of directly related expenses when calculating the withholding tax due over cross-border royalty payments
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On March 12, 2025 the European Commission published the key decisions of the March 2025 infringements package. One of the decisions published is the decision of the European Commission to to send a reasoned opinion to Spain (INFR(2021)4042), for failure to align its rules on withholding taxes charged on royalty payments received by non-resident taxpayers with the freedom to provide services (Article 56 TFEU).
The European Commission decides to refer Spain to the CJEU due to discriminatory tax treatment of non-resident taxpayers
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On March 12, 2025 the European Commission published the key decisions of the March 2025 infringements package. One of the decisions published is the decision of the European Commission to refer Spain to the Court of Justice of the European Union (the CJEU) for having failed to remedy an infringement in relation to the free movement of capital (Article 63 TFEU) due to a discriminatory tax treatment of non-resident taxpayers.
The UK notified Belarus and the Russian Federation about its intention to suspend the DTAs with those jurisdictions
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On February 4, 2025 on the website of the UK HM Revenue & Customs 2 updates were published. In these updates it is announced that the UK has notified Belarus and the Russian Federation of its intention to suspend the DTAs that are in place between the UK and those 2 jurisdictions.
