Home My IBFD Content Search Products Courses Services About IBFD Contact
The Netherlands in International Tax Planning
(Second Revised Edition)
Author: Johann Muller

Summary

This second edition of The Netherlands in International Tax Planning has been necessitated by the substantial amendments introduced to the Dutch corporate income tax system per 1 January 2007. These changes include a considerable revision of the participation exemption and several changes to Dutch interest limitation rules. In addition, a 10% royalty income box has been introduced and a 5% interest income box proposed; the interest income box still needs the blessing of the European Union. Dutch capital duty was already abolished per 1 January 2006. This book discusses current law only.

Similar to the first edition, the book provides a practical guide on dealing with the Dutch taxation of businesses investing into, via (conduit structures), or from the Netherlands. The book focuses on corporate income tax and dividend tax as well as on other issues typical of an international environment. Where relevant, the link between Dutch law and European law on direct taxation is also mentioned. Several examples of practical structures and calculations are given in order to enhance the reader’s understanding.

View sample chapter    |    View table of contents

The second edition of The Netherlands in International Tax Planning is an indispensable tool for corporate foreign investors, international tax practitioners, tax advisers and lawyers involved in cross-border transactions to or from the Netherlands. It is a valuable reference work for academics and all those interested in gaining a better understanding of the Dutch tax legislation.
Main Contents
  • An introduction to Dutch domestic law, including both corporate and personal income tax, dividend withholding tax, capital duty, real estate transfer tax.
  • An in-depth analysis of the Dutch corporate income tax system including financing a taxpayer, tax consolidation, holding companies and participation exemption, corporate reorganizations, financing companies, transfer pricing, loss compensation, inbound investments and anti-abuse legislation.
  • Recent changes to Dutch participation exemption, abolishment of capital duty, abolishment of hybrid loan legislation, changes to Dutch interest limitation rules are highlighted.
  • An overview of Dutch international law examining treaties, the tax agreement for the Kingdom of the Netherlands, the unilateral decree for the prevention of double taxation and EU law.
  • A description of Dutch dividend tax including EU entities and dividend tax credit.
  • An overview of the exchange of information including national law, the ruling practice, treaties and EU law.
  • A description of the personal income tax, including 30% cost allowance and employee stock option plans.
About the Author

Johann Müller works as in-house counsel in international taxation for the A.P. Moller-Maersk group. Prior to this he worked at various large Dutch tax firms, both in the Netherlands and abroad, specializing in international taxation with a focus on mergers and acquisitions, international reorganizations and cross-border leasing. Mr Müller is an active teacher and has spoken regularly at international tax conferences.

Other books in the International Tax Planning Series
IBFD Newsletter
Receive free monthly updates on products and services in the world of international taxation? Read the most recent issue or subscribe.
View the newsletter archive.
Customer Service
Clients worldwide:
Tel.: +31-20-554 0176
Fax: +31-20-620 8626
E-mail: Customer Service

North and Latin American clients:
Tel.: +1-703-442 7757
Fax: +1-703-442 7758
E-mail: IBFD USA
Terms & Conditions
The general terms and conditions of IBFD are available here.
Purchasers of this book were also interested in:

Fundamentals of International Tax Planning [book] Authors: Chris J. Finnerty; Paulus Merks; Mario Petriccione; Raffaele Russo

International Tax Policy and Double Tax Treaties [book]

Author: Kevin Holmes

European Taxation Database [online] is a complete database of tax information, practice and analysis.

Principles in international Taxation [course]

June 2 - 6, 2008

Kuala Lumpur

European Tax Handbook [book] Editor: Juhani Kesti

Global Tax Explorer [online] seamlessly links the world’s most extensive and accurate source of tax treaties with global tax surveys, a daily tax news service, tax treaty case law, an extensive glossary and an online tax calculation tool.