The Dutch Minister of Finance presented the 2025 budget to the parliament on 17 September. A number of changes are anticipated as part of the Tax Plan 2025.
Some of the most significant proposed changes include:
- New group definition in the Withholding Tax Act;
- Extension of the definition of a related party in the CIT Act;
- Implementation of the OECD Pillar II guidelines in the Minimum Tax Act;
- Correction of provisions on deductibility of interest payments in the CIT Act;
- Abolition of the reduced VAT rate for certain transactions;
- Partial reversal of the restrictions in the 30% allowance scheme.
In addition, a number of new provisions take effect from 1 January 2025, including:
- Changing the fiscal classification of the so-called open limited partnerships, which will be treated as transparent for CIT purposes;
- Tightening of the regime for exempt investment entities (VBIs) by excluding family structures;
- Exclusion of direct investments in Dutch real estate from the fiscal investment units (FBI) regime;
- Introduction of Country-by-Country Reporting for the largest multinationals;
- Abolition of the partial foreign taxpayer status which entitled Dutch tax residents to Box 2 & 3 exemptions.
Do not hesitate to contact us should you require a detailed analysis of the issues of your particular interest.