Position Papers of the Dutch Tax Authorities
Position paper of a knowledge group of the Dutch tax authorities on the question whether assigned parking locations in relation to the rental of means of transport qualify as a PE?
In this article we discuss position paper KG:040:2022:9 of January 31, 2023. In this position paper the Knowledge Group on international taxation, corporate income tax & the taxation of profits of the Dutch tax authorities answers the question whether in its view parking locations in combination with the rental of means of transport by a foreign company, constitute a permanent establishment in the Netherlands.
Position paper of a knowledge group of the Dutch tax authorities on whether the Interest and Royalties Directive applies in a certain situation
In this article we discuss position paper KG:040:2022:5 of June 17, 2022. In this position paper the Knowledge Group on international taxation, corporate income tax & the taxation of profits answers the question whether in its view the Interest and Royalties Directive precludes the taxation of interest received by a company that was incorporated under Dutch law and that has relocated to Belgium and which legal form was converted into a BVBA (Belgian legal form) from an indirect subsidiary that is a resident of the Netherlands.
Position paper of the Dutch tax authorities’ knowledge group on production costs that have been amortized at once and the second limit for the credit method to avoid double taxation
In this article we discuss position paper KG:040:2022:4 of June 17, 2022. In this position paper the Knowledge Group on international taxation, corporate income tax & the taxation of profits answers the question whether based on the matching principle for the calculation of the second limit, production costs of intangible assets, which pursuant to Article 8, Paragraph 1 of the Dutch Corporate Income Tax (DCIT) Act in conjunction with Article 3.30, Paragraph 3 of the Dutch Individual Income Tax (DIIT) Act, have been fully amortized in the calendar year of production, must be allocated to years other than the calendar year of production.
Position paper of a knowledge group of the Dutch tax authorities regarding non-deductible interest expenses and the second limit for the credit method to avoid double taxation
In this article we discuss position paper KG:040:2022:1 of April 21, 2022. In this position paper the Knowledge Group on international taxation, corporate income tax & the taxation of profits answers the question whether non-deductible interest expenses should also be deducted from the foreign income that qualifies for the second limit for the credit to be granted with respect to withholding taxes that have been withheld by a foreign jurisdiction.
Position paper of the Dutch tax authorities’ knowledge group on withholding taxes regarding a share buy-back against an uncertain future remuneration
In this article we discuss position paper KG:024:2023:9. In this position paper the Knowledge Group on dividend withholding tax and other withholding taxes answers the question at which moment and over which amount Dutch dividend withholding tax is due if the share buy-back takes place against cash and a right to future payments of which the size is still uncertain.
