The Dutch House of Representatives approved a budget proposal on 11 November which included an approval vote on the government’s tax proposals for 2022 and beyond – some of which are relevant for multinational corporations.

The documents include a proposal to implement the reverse hybrid mismatch rules from the EU’s Anti-Tax Avoidance Directive II (ATAD – in force from 1 January 2022).

In brief:

  • The government has voted to increase the upper bracket corporate tax rate from 25% to 25.8%
  • Interest deductibility under the EBITDA rule (introduced as part of EU Anti-Tax Avoidance Directive I) has decreased from 30% to 20% of the taxpayer’s EBITDA (earnings before interest, taxes, depreciation and amortisation).
  • Unilateral downward transfer pricing adjustments are now limited in cases where there is no corresponding taxable adjustment.

The proposals are yet to pass the Senate but, as the Dutch Senate cannot amend legislative proposals, they are seen as final. The Senate is expected to vote in mid-December.

If you’d like more information or help with your Netherlands tax compliance, simply get in touch.

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Francisco Javier Curto Martin
Senior Manager. Tax Support

Local Knowledge – International Coverage

Founded in 1979, Auxadi is a family-owned business working for multinational corporations, private equity funds and real estate funds. It’s the leading firm in international accounting, tax compliance and payroll services management connecting Europe and the Americas with the rest of the world, offering services in 50 countries. Its client list includes many of the top 100 PERE companies. Headquartered in Madrid, with offices in US and further 22 international subsidiaries, Auxadi serves 1,500+ SPVs across 50 jurisdictions.

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