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In a letter sent to the Dutch Parliament on July 6, 2023 the Dutch Secretary of State for Finances informed the House of Commons that he intends to make the following (minor) adjustments to the regulations applying to rulings with an international character. In his letter to the House of Commons he states that he intends to have the Decree amending the existing Decree to be published in the beginning of October 2023. Publication in the Dutch State Gazette is necessary for the intended adjustments to enter into force.
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On June 29, 2023 on the website of the Dutch Courts the judgment of the Court of Appeal of Amsterdam (hereafter: the Court) in Case 22/00232, ECLI:NL:GHAMS:2023:1399, was published. In the underlying case the taxpayer and the tax authorities are disputing whether or not the taxpayer is allowed to divide the goodwill it acquired via an international legal merger into 2 parts and to capitalize one of these parts on the balance sheet of its Dutch head office and subsequently take amortization costs into account for Dutch corporate income tax purposes with respect to this capitalized goodwill.
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According to Swiss Parliament, the loss carry forward period for companies is to be extended from 7 to 10 years. This to enable companies affected by the corona pandemic to recover better. In this respect the Swiss Federal Council has worked out the legal amendments and opened a consultation on June 28, 2023. The consultation period runs until October 19, 2023.
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On June 30, 2023 the Dutch Minister of Finance sent to the Dutch parliament an annotated agenda for the Eurogroup and Economic and Financial Affairs (ECOFIN) Council meetings that will take place on respectively July 13, 2023 and July 14, 2023. One of the agenda points the Dutch Minister of Finance discusses is the reallocation of taxing rights (Pillar 1). In this respect the Dutch Minister of Finance states a.o. the following:
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