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ARTICLE · 25 JULY 2019

Revised Ruling Policy Effective As Of July 1, 2019

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On June 28, 2019, the Dutch State Secretary of Finance published a revised decree revising the ruling policy on the basis of which advance certainty

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On June 28, 2019, the Dutch State Secretary of Finance published a revised decree revising the ruling policy on the basis of which advance certainty may be obtained regarding certain matters of corporate income tax, dividend withholding tax and tax treaties. The new policy will be effective as of July 1, 2019 and applies to rulings with an international character.

The amended ruling policy applies to the following matters 

  1. The application of the participation exemption with respect to shareholdings in non-resident companies;
  2. Qualification of hybrid financing arrangements or hybrid entities in international structures;
  3. The application of the CFC rules implemented on the basis of the Anti-Tax Avoidance Directive (ATAD) and the related credit for foreign taxes;

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