INTERNATIONAL TAX PLAZA - Withholding taxes

List of articles in category Withholding taxes
Title	Published Date
Position of the Dutch tax authorities on the manner in which treaty benefits can be claimed with respect to a share buyback if, based on the capital gains article of a treaty, the levying rights are not allocated to the Netherlands	02 January 2024
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	01 December 2023
A position paper of the Dutch tax authorities regarding the withholding exemption for Dutch dividend withholding tax purposes and the ‘residing there’ criterion	13 November 2023
The Dutch tax authorities published its position the definition of ultimate beneficial owner for dividend stripping purposes	12 November 2023
Position paper of a knowledge group of the Dutch tax authorities regarding the withholding of dividend withholding tax over the repayment of share premium	09 October 2023
Position paper of a knowledge group of the Dutch tax authorities regarding the withholding exemption within a fiscal unity	09 October 2023
Position paper of a knowledge group of the Dutch tax authorities on the question whether an open limited partnership can make a tax exempt repayment of capital if it has a net profit available	30 June 2023
Position paper of the Dutch tax authorities’ knowledge group on withholding taxes regarding a share buy-back against an uncertain future remuneration	21 May 2023
Position of the Dutch tax authorities on the question whether a Total Return on Equity Swap qualifies as a share buy-back for Dutch dividend withholding tax purposes?	17 May 2023
Position paper of the knowledge group of the tax authorities on withholding taxes – Position of the Dutch tax authorities if the beneficiary body is another one than the lender of the loan	16 May 2023

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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