On September 15 2011, the Dutch government published its 2012 budget proposals. The proposals include further limitations on the tax deduction of interest payments by acquisition holding companies and the introduction of a revised exemption for foreign branch profits. In addition, anti-abuse provisions are proposed in connection with the taxation of non-Dutch resident corporate shareholders in Dutch companies and the levy of dividend withholding tax on certain profit distributions made by Dutch co-operatives. René van Eldonk and Steven den Boer of Simmons & Simmons analyse the proposals.
Unlock this content.
The content you are trying to view is exclusive to our subscribers.
A revised Chapter VII signals a move away from mechanical TP approaches, stressing transaction understanding, functional analysis and context-driven documentation requirements
HMRC’s growing focus on evidencing tax decisions is shifting attention from technical accuracy to governance, requiring businesses to demonstrate how positions were reached and documented
Australia’s Department of Finance will also commission an independent review of KPMG’s governance, culture, ethics and integrity frameworks, it has revealed
In the second instalment of this two-part series, Jayne Stokes takes a practical approach to navigating the capital v revenue question for UK R&D claims for software development, and shares pointers for businesses
ITR's latest podcast considers how transformational the buyout could be in Ryan's quest for global advisory reach and analyses a recent boom in demand for private client advisory services