Dutch Tax Plan 2022: Direct Taxes

ABSTRACT

On 22 September 2022; the third Tuesday of September the Dutch Budget Day Plan for 2022 was introduced by the government. This Budget Day Plan also consists out of the Tax plan 2022. In this plan new legislations and amendments have been added with regard to Direct taxed like the Corporate Income Tax Act and the Dividend Withholding Tax act. These amendments and legislations concern new CIT rates, ATAD2 legislation, mismatches in transfer pricing, CFC measures and loss offset rules.

Key words: CFC, Reversed Hybrid Mismatch, Carry Forward, Dutch Tax Plan 2022, Arm's Length Principle

INTRODUCTION

During the Dutch Budget Day 2022, on the third Tuesday of September, the Dutch parliament presented its Tax Plan 2022. Because the Netherlands currently has a caretaker government, there have not been many new or major decisions and changes with regard to taxes. This year there are mainly small(er) changes, which will improve the tax system. In particular,