Netherlands: 2023 Spring Memorandum proposed direct and indirect tax measures

Spring Memorandum 2023 highlights a number of proposed direct and indirect tax changes

Spring Memorandum 2023 highlights a number of proposed direct and indirect tax changes

The Spring Memorandum 2023 published on 28 April 2023, highlights a number of proposed direct and indirect tax changes relating to:

  • Real estate
  • Business succession arrangements
  • Box 3
  • Additional margin scheme and the place of virtual services for sales tax
  • Adjustment of minimum capital rule for internal treasury and percentage increase
  • Energy investment allowance (EIA) deficiency and coverage
  • Extension of the application of the reinvestment reserve (HIR) regarding cessation schemes
  • Abolition of income tax payment discount
  • Dividend stripping approach

KPMG observation

The 2023 Spring Memorandum provides a preview of the fiscal measures that are planned in the short and somewhat longer term.

Property owners in particular are taxed much more heavily. However, substantial interest holders can be pleased that the business succession arrangements will continue to exist and that a number of technical points will be cleared up.

Box 3 remains a complicated issue. As long as a tax based on actual yield has not been introduced and the difference between the tax boxes has not been mitigated, tax-driven behavior will continue and the tax authorities will want to take action against this, or taxpayers will litigate.

Read a May 2023 report prepared by the KPMG member firm in the Netherlands


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