Netherlands: Amendments to corporate income tax, withholding tax proposed for 2022 Tax Plan

Amendments to the “2022 Tax Plan” presented to the lower house of Parliament

Amendments to the “2022 Tax Plan” presented to the lower house of Parliament

Amendments to the “2022 Tax Plan” were presented on 5 October 2021 to the lower house of Parliament.

The tax plan memorandums were announced on Budget Day. Read TaxNewsFlash

The amendments concern the following:

  • Corporate income tax
    • Adjustment of pre-fiscal unity loss set-off against the profit of subsidiary included upon incorporation in the fiscal unity
    • Note that a further memorandum of amendment is expected on 15 October 2021 to implement the “Hermans motion.” Several additional measures could also be proposed, such as lowering the earnings stripping percentage to 20% and increasing the top corporate income tax rate to 25.8%.
  • Withholding tax on interest and royalties
    • Expansion of permanent establishment concept as of 2022
    • Clarification of rebuttal provision hybrid measure
  • Real estate transfer tax

Read an October 2021 report prepared by the KPMG member firm in the Netherlands


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