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Netherlands: Foreign tax credits to alleviate double taxation of assets from trusts (APVs)

Effective retroactively from October 3, 2024

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January 14, 2026

Decree No. 2025-27737 (published on November 5, 2025) grants foreign tax credits under income tax treaties to alleviate double taxation of assets from trusts (APVs).

This applies even when tax treaties do not resolve the issue, allowing credits for foreign taxes to offset Dutch income tax, effective retroactively from October 3, 2024.


For more information, contact a KPMG tax professional in the Netherlands:

Michael van Gijlswijk | vangijlswijk.michael@kpmg.com

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