A Quick Guide To Reverse Charges Across Europe

The OECD has released new administrative guidance on Pillar Two's Global Anti-Base Erosion (GloBE) Rules, addressing explicitly conditional taxes and QDMTT safe harbour operations. The package includes an updated GloBE Information Return incorporating permanent safe harbours and establishes a peer review framework for assessing whether domestic legislation aligns with international standards.

There are 98 income tax treaties in force in the Netherlands. In addition, the Netherlands has signed several income tax treaties that are expected to enter into force in the future.

The Dutch government has released its comprehensive tax plan for 2027, introducing significant changes across corporate income tax, dividend withholding tax, Pillar 2 implementation, employment taxation, and real estate transfer tax. Key measures include modifications to the participation exemption regime for hedging instruments, implementation of the OECD Side-by-Side Safe Harbour package for US-headed multinational groups, and new stock option schemes for startups and scale-ups designed to strengthen the

Het Nederlandse kabinet kondigt ingrijpende fiscale hervormingen aan voor box 3 en box 2, met een versnelde overgang naar een vermogenswinstbelasting vanaf 2028 en aanpassingen aan het heffingsvrij vermogen. Daarnaast worden maatregelen gepresenteerd voor versterking van de koopkracht van werkenden en het terugdraaien van eerder voorgenomen hervormingen in de sociale zekerheid.

年度汇算清缴向来是所得税管理的重点和难点，尤其由于疫情原因，国内外企业的正常运营都受到很大影响，更为2019年度汇算带来了新的挑战。

The Dutch government has unveiled its Tax Plans 2027, introducing significant changes for corporate taxpayers including retroactive implementation of the Side-by-Side package and modifications to participation exemption rules for foreign currency hedging. The proposals emphasize innovation through enhanced tax benefits for SMEs and improved treatment of employee share options in start-ups, though their adoption faces uncertainty given the government's lack of parliamentary majority.

The Netherlands has introduced public country-by-country reporting requirements for large multinational groups with consolidated revenue above EUR 750 million. These new rules will make tax data publicly accessible through the Dutch trade register, allowing journalists, NGOs, investors and competitors to review tax information by jurisdiction. Groups with a calendar financial year must publish their first report by the end of 2026, covering the 2025 financial year.

The Dutch government has introduced several tax measures aimed at transforming the residential real estate market, including a reduction in transfer tax rates for investment properties and new subsidies for mid-rent housing development. These proposals seek to address housing shortages by improving investment conditions and facilitating cooperation between housing associations through targeted tax exemptions and enhanced borrowing capacity.

The Dutch Supreme Court has ruled that unrealised losses fall within the scope of the Loss Restriction Rule, creating new administrative challenges for taxpayers who must now identify, value and monitor such losses at the time of qualifying ownership changes. While the judgment clarifies this principal issue, it leaves several technical questions unresolved, particularly affecting real estate structures, asset-intensive businesses and distressed M&A transactions.

A new Dutch policy decree clarifies when remote working arrangements may create a permanent establishment for foreign employers, following recent amendments to the OECD Model Tax Convention. The guidance establishes a 50% threshold test and introduces case-by-case assessment criteria that could significantly impact cross-border employment taxation and corporate tax liability for businesses with remote workers.