INTERNATIONAL TAX PLAZA - International taxation

List of articles in category International taxation
Title	Published Date
Position of the Dutch tax authorities on the Portuguese Non-Habitual Resident regime and the residency for tax treaty purposes	28 February 2024
Position of the Dutch tax authorities on the timing of the deduction of a discontinuation loss incurred with respect to a permanent establishment if the foreign compensation for the loss is only established after the year of discontinuation	04 January 2024
Position paper of a knowledge group of the Dutch tax authorities: “A notional Brazilian withholding tax (tax sparing credit) cannot be deducted as costs in the Netherlands”	30 June 2023
Position paper of a knowledge group of the Dutch tax authorities regarding the settlement of German withholding tax withheld under the Dutch-German DTA over interest received on a mezzanine loan	25 June 2023
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?	30 May 2023
Position paper of a knowledge group of the Dutch tax authorities on whether the Interest and Royalties Directive applies in a certain situation	29 May 2023
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	23 May 2023
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	22 May 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