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On June 3, 2025 we reported on 3 judgments of the Court of Appeal of The Hague on the relevance of the outcome of a Mutual Agreement Procedure for earlier years (See our article of June 3, 2025). These 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”.
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On October 9, 2025 the European Parliament adopted a resolution containing suggestions for reforms to the tax architecture to boost competitiveness while continuing to address tax avoidance and evasion. A report, drafted by Michalis Hadjipantela, was debated on October 8, 2025 in plenary and adopted on October 9, 2025 by 499 votes in favour, 66 votes against and 53 abstentions. The resolution will feed into the ongoing legislative work on legislative simplification, more particularly a dedicated proposal of the European Commission that is expected in early 2026.
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On October 10, 2025 the European Council approved conclusions on the use of tax incentives to support clean technologies and industry as part of the EU’s clean industrial deal. The conclusions respond to a Commission recommendation on the topic, which was published on July 2, 2025.
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On October 3, 2025 The Dutch Government opened a public consultation on the proposal for a Bill implementing the deemed supplier measures of the VAT in the Digital Age (ViDA) package. The bill implements Paragraphs 1, 2, 3, 4, 6, 10, and 14 of Article 3 of the ViDA Directive (Council Directive (EU) 2025/516 of 11 March 2025 amending Directive 2006/112/EC as regards VAT rules for the digital age). The Consultation period runs from October 3, 2025 up to and including November 3, 2025.
