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Last updated : 11-06-2026

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Refund of Dutch dividend withholding tax for UK Insurer
27 May 2026

Corporate Structuring

The Court of Appeal of ’s-Hertogenbosch has held that a UK-based unit-linked insurer is entitled to a refund of € 53,775,031 in Dutch dividend withholding tax. The decision is particularly relevant because, in line with the CJEU’s preliminary ruling, the court confirms that Article 63 TFEU may preclude Dutch dividend withholding tax where a comparable Dutch resident company would, in net terms, not bear tax on the same dividends.
EU VAT treatment of cross border transfer pricing adjustments
27 May 2026

Corporate Structuring

The Court of Justice of the European Union held that a transfer pricing adjustment within a group does not automatically constitute consideration for a VATable service. The key question is whether there is a legal relationship involving reciprocal performance and a direct link between an identifiable service and the remuneration received.
Participation exemption: advisory costs linked to price adjustment clauses not tax deductible
27 May 2026

Corporate Tax Services

Accounting & Corporate Secretarial Services

Corporate compliance

Transfer Pricing Services

Corporate Structuring

Participation exemption: Dutch Tax Administration withdraws position on advisory costs linked to price adjustment clauses
Refund Dutch dividend withholding tax for stock dividends (bonus shares) to foreign individual shareholders
13 May 2026

Corporate Tax Services

Global Mobility Services

Corporate Structuring

International Tax Planning

International labor and cross border assignments

Tax compliance

Netherlands

The Dutch tax office confirms the refund of Dutch dividend withholding tax for stock dividends (bonus shares) issued to foreign individual shareholders

Broad application of Article 10a CITA and fraus legis in Dutch cross-border interest deduction cases
13 May 2026

Corporate Tax Services

Accounting & Corporate Secretarial Services

Transfer Pricing Services

Corporate Structuring

Transfer Pricing

International Tax Planning

Mergers & Acquisitions

Tax compliance

Netherlands

The Dutch Supreme Court rules that the general Dutch anti-abuse provision of Fraus Legis can be applicable next to the specific anti-abuse provision of art. 10A CITA.

Spanish AIE Treated as Tax-Transparent for Dutch Tax Purposes
28 April 2026

Corporate Tax Services

Corporate Structuring

International Tax Planning

Mergers & Acquisitions

Spain

Netherlands

The Dutch Tax Authorities have clarified that a Spanish Agrupación de Interés Económico (AIE) qualifies as a tax transparent entity for Dutch tax purposes
Update on the Netherlands’ tax treaty negotiations in 2026
28 April 2026

Corporate Tax Services

VAT advice & compliance

Payroll & HR services

Global Mobility Services

Corporate compliance

Fiscal Representative for VAT

Corporate Structuring

International Tax Planning

Mergers & Acquisitions

International labor and cross border assignments

Belgium

Spain

Romania

Germany

Bangladesh

Brazil

Surinam

Thailand

Sweden

Portugal

Aruba

The Dutch State Secretary for Finance informed Parliament about the status of treaty negotiations with other countries in 2026

Dutch tax measures Middle East crisis
28 April 2026

Corporate Tax Services

VAT advice & compliance

Payroll & HR services

Global Mobility Services

Corporate compliance

Corporate Structuring

International Tax Planning

Mergers & Acquisitions

Tax compliance

United Arab Emirates

Netherlands

The Dutch government has announced an action plan to mitigate the economic fallout from the conflict in the Middle East, including a package of tax measures.
Dutch list of recognised developing countries for 2025
28 April 2026

Corporate Tax Services

Corporate compliance

Corporate Structuring

International Tax Planning

International accounting

Tax compliance

Netherlands

The State Secretary for Finance has published the list of developing countries designated for the purposes of Article 6 of the 2001 Decree for the Avoidance of Double Taxation (Bvdb 2001) for the year 2025. Compared with the 2024 list, Kyrgyzstan has been removed and no new countries have been added.
Brazilian Interest on Net Equity (IoNE)
14 April 2026

Corporate Tax Services

International Tax Planning

Brazil

The Netherlands qualifies the Brazilian Interest on Net Equity (IoNE) as dividend eligible for a 25% tax spearing credit provided by the tax treaty between Brasil and the Netherlands.