INTERNATIONAL TAX PLAZA - Dutch corporate income tax

List of articles in category DCIT
Title	Published Date
Standpunt van de Kennisgroep deelnemingsvrijstelling gepubliceerd over een artikel 13, zevende lid, Wet Vpb beschikking en een non-deliverable valutatermijncontract	18 June 2024
Standpunt van de Kennisgroep deelnemingsvrijstelling gepubliceerd over de toepassing van de deelnemingsvrijstelling op voordelen uit een optierecht met een geleidelijke uitoefeningsmogelijkheid	18 June 2024
Position of the Dutch tax authorities on the application of the liquidation loss scheme in case of the dissolution and liquidation of an entity that previously was a sub-subsidiary of the taxpayer	29 March 2024
Position of the Dutch tax authorities on the question whether a result on a forward exchange contract constitutes a part of the cost price of a participation	12 February 2024
A position paper of the Dutch tax authorities on the carrying-back of losses for Dutch corporate income tax purposes has been published	15 November 2023
Position paper of a knowledge group of the Dutch tax authorities regarding the application of Articles 10c and 25 of the DCIT Act in relation to a Total Return on Equity Swap	22 June 2023
Position paper of a knowledge group of the Dutch tax authorities on the treatment for Dutch corporate income tax purposes of certain Phantom Stocks	07 June 2023
Position paper of a knowledge group of the Dutch tax authorities on the qualification of a reverse convertible loan for Dutch corporate income tax purposes and the deductibility of the surcharge paid for the conversion right	07 June 2023

INTERESTING ARTICLES

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)
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
The Inclusive Framework on BEPS 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
The DAC9 Directive has been published in the Official Journal of the European Union
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
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
The Council of the European Union adopted the DAC9 Directive
The CJEU ruled in Case C-228/24, Nordcurrent group (The anti-abuse provision of the Parent-Subsidiary Directive)
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)
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)
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
The European Commission decides to refer Spain to the CJEU due to 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