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Improving the investment climate is at the top of the agenda of the three political parties (D66, CDA and VVD, the Coalition) that will form the new government of the Netherlands.

US multinational enterprises acquiring Dutch targets often file CTB elections to treat the target as a disregarded entity for US tax purposes, but this seemingly straightforward step can trigger complex Dutch tax implications. From anti-hybrid mismatch rules and transfer pricing considerations to dividend withholding tax exemption eligibility, the interaction between US and Dutch tax regimes requires careful navigation to avoid double taxation and ensure tax-neutral transactions.