INTERNATIONAL TAX PLAZA - International taxation

List of articles in category International taxation
Title	Published Date
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

Position paper of the Dutch tax authorities on the crediting of foreign withholding taxes withheld over rental payments for forklift tractors, trucks, containers and pallets
Again the proposal for an unshell Directive is missing on the provisional agenda of the next ECOFIN Council
The Netherlands – Decree regarding the Earnings stripping measure published in the Dutch State Gazette
Besluit van de staatssecretaris van 24 november 2023 inzake de earningsstrippingmaatregel (Besluit Earningsstrippingmaatregel) gepubliceerd
The Dutch Supreme Court ruled on earn-outs and loss settlement possibilities in case of a pure holding/financing entity that was involved in a legal merger
The OECD released the Corporate Tax Statistics 2023 and the accompanying working paper “New evidence on global low-taxed profit”
OECD: “Jurisdictions with statutory and average tax rates above 15% – account for more than half of all global profits currently taxed below 15%”
Position of the Dutch tax authorities on the Dutch dividend withholding tax consequences of the repurchase of outstanding shares to hedge a potential conversion obligation that exists under a convertible bond
Key decisions of the November 2023 infringements package published
A position paper of the Dutch tax authorities on the carrying-back of losses for Dutch corporate income tax purposes has been published
Kuwait joins the Inclusive Framework on BEPS and joins in the agreement to implement the Two-Pillar Solution
The OECD released the 2022 Mutual Agreement Procedure Statistics
A position paper of the Dutch tax authorities regarding the withholding exemption for Dutch dividend withholding tax purposes and the ‘residing there’ criterion
De belastingdienst heeft een standpunt gepubliceerd over de toepassing van de inhoudingsvrijstelling voor bronbelastingen en het criterium aldaar gevestigd