Dutch budget: complex tax legislation that goes too far

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.