Traditionally, the Dutch government presents its budget plan to parliament on the third Tuesday in September. It contains tax proposals for the coming year (the 2025 tax plans). In this article, we address elements of the 2025 tax plans relevant to U.S. multinational enterprises or U.S. investment funds with Dutch entities in their structure. The article begins by addressing relevant changes to the Dutch tax code, specifically concerning the earnings stripping rule. We then set out amendments to the Dutch tax code that facilitate the interaction between certain Dutch subject-to-tax tests (STTs) and the OECD’s global anti-base-erosion (GLOBE) model rules. Subsequently we address the main changes in connection with Dutch withholding taxes and legislation on the tax classification of entities that is already enacted and comes into effect in 2025. We conclude by briefly highlighting some other elements of the 2025 tax plans.
Download their article below and don’t hesitate to reach out to our experts if you want to know more about this topic. This article was first published by Tax Notes International.
