Sebastiaan Wijsman MRE

📊 Budget Day 2025 Update: Key Tax Changes You Need to Know! Today marks an important moment for businesses in the Netherlands. On this Budget Day, the government published the tax plans for 2025. One significant change to highlight is the adjustment in the interest deduction limitation rule, commonly known as the ‘earnings stripping rule.’ 🔹 What’s Changing? The permissible limit for deductible excess interest expenses will increase from 20% to 25% of the adjusted Dutch taxable profit (EBITDA for tax purposes). This adjustment offers a more lenient approach towards the financing costs businesses can deduct. 🔹 Thresholds and Conditions The earnings stripping rule will maintain its threshold where excess interest expenses up to EUR 1,000,000 are not restricted. Additionally, any excess can still be carried forward without limitation, providing flexibility for future fiscal years. 🔹 Special Focus on Real Estate A notable stipulation in the new tax plan targets real estate businesses. If a taxpayer’s adjusted property mainly consists of immovable property for at least half of the year and is made available to someone other than related entities or associated persons, these changes will particularly impact how these assets are taxed. 🔍 Implications These changes could have profound implications for financing strategies and tax liabilities, particularly for businesses heavily invested in real estate or those with significant financing costs. 💬 I’m keen to hear your thoughts on how these changes will impact our industry and your business. Let’s discuss below! #NetherlandsTax #BudgetDay2025 #Finance #BusinessTaxation

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Our tax experts, Michiel Schul and Laurens Hoek, contributed an insightful article, "Impact of the Dutch 2025 Tax Plans on U.S. Parties," to the latest edition of Tax Notes. In this article, Michiel and Laurens break down how the 2025 Dutch tax proposals could benefit U.S. multinationals and asset managers with Dutch entities. Key topics include: ➡️ Changes to the Dutch earnings stripping rules. ➡️ Amendments to the ‘subject-to-tax rules’ in interest deduction limitation rule (article 10a) and the participation exemption to recognize the Pillar Two (P2) levy in a particular jurisdiction as ‘tax paid’. ➡️ Incorporation of new P2 OECD Administrative Guidance under P2 in Dutch tax law. This includes changes on the P2 treatment of new categories of tax credits, the substance-based income exclusion and hybrid arbitrage arrangements entered into after December 15, 2022. ➡️ Positive changes to the conditional withholding tax rules by the introduction of a narrower group concept (the so-called ‘qualifying unit’). This is good news for US asset managers with investment platforms in the Netherlands. ➡️ Changes to the Dutch entity classification rules. These rules are generally positive news as they are expected to reduce the number of hybrid mismatches in an international context. The new entity classification rules were already adopted last year but will become effective on January 1, 2025. Want to check how these developments impact your structure? Read our article here: https://lawand.tax/4938izh #lawandtax #InternationalTax #USNetherlands #2025Dutchtaxplans

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On 24 September 2024 tax practitioners from business and consultancy had an informal meeting in Rotterdam to discuss what is next after the silent collapse of Pillar One. The exercise resulted in an exploration of #developments, culminating in a call for some renewed thinking on company #tax reform by seeking a tax-equilibrium through competition rather than through coordination, since this is how the world seems to be working. One of the participants, Maarten Floris de Wilde, wrote a blog about the meeting for the Kluwer International Tax Blog! #taxlaw #taxreform #pillarone

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The Dutch Tax plan 2025 published today includes several proposals that are relevant for international companies. The key topics are discussed in below Deloitte alert.

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𝗧𝗮𝘅 𝗣𝗹𝗮𝗻 𝟮𝟬𝟮𝟱 The Dutch government has presented its 2025 Tax Plan (Belastingplan 2025). Key elements include adjustments of the personal income tax brackets, an income tax reduction for income on shares, an increase of VAT on sport, books, lodging and cultural activities and a decrease of transfer tax on homes. Read the article on our website https://bit.ly/taxplan2025 For more information, please contact Maarten Tervoort ([email protected]) or Giordy Janga ([email protected]) #HBNlawandtax #LegalServices #TaxServices #Tax #DutchCaribbean #TheNetherlands #TheHague #TaxPlan2025 #FiscalChanges

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As from 2025, as a main rule, Dutch (commanditaire vennootschap; 𝗖𝗩𝘀) and foreign limited partnerships will be classified as transparent for Dutch tax purposes, except when a limited partnership should be considered a fund for joint account (fonds voor gemene rekening; 𝗙𝗚𝗥). In case of the latter, both a tax transparent and a non-transparent classification remain to apply as from 2025.   Due to the prevailing classification of the FGR, under circumstances, tax transparent limited partnerships that are ’investment funds’ (𝗙𝘂𝗻𝗱 𝗟𝗣𝘀) may transition into a non-transparent FGR as of 2025, however only when also possessing the other key characteristics of an FGR. Want to know more? Please see our website post: https://lawand.tax/3Yo3C25 For more information, please contact Michiel Beudeker, Robert Veenhoven, Marco de Lignie, Ton Stevens, Wouter van der Leij, Erik Kastrop or Thomas Moolhuijsen. #tax #privateequity #investments #jointaccount #lawandtax

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On April 23 the Dutch tax authorities released a very important new decision regarding the transitional law for the 30% ruling and the 30/20/10 reduction introduced per January 1, 2024. It has long been unclear whether the transitional law applies if the 30% ruling is not yet applied in the payroll during the request period of the ruling. It is now officially confirmed that the transitional law also applies in situations when the 30% ruling is effectuated in the payroll with retroactive effect. This decision also applies for the salary cap introduced per 2023. Check the full article here: https://lnkd.in/evWhD3Yg Want to know more? Please contact Maarten de Vries or Yvonne Bakker.  #atlasfiscalisten #ruling #payroll #wagetax #wtsglobal #transitionallaw 

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On November 14, 2024, the Lower House of the Dutch Parliament passed the 2025 Tax Plan package. Various amendments and motions were also adopted. In our memorandum we describe the main changes achieved by the adopted amendments and explain several of the motions. #tax #updates #Meijburg #KPMG

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𝗙𝗶𝗻𝗮𝗻𝗰𝗲 𝗕𝗶𝗹𝗹 𝟮𝟬𝟮𝟰 - 𝗜𝗻𝗱𝗶𝗿𝗲𝗰𝘁 𝗧𝗮𝘅 𝗶𝗻𝘀𝗶𝗴𝗵𝘁𝘀 Read our insights on the VAT exemption for the management of EU funds, Excise Duty, VRT and more here: https://lnkd.in/eXbdh7GW

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An important (and welcome) state aid decision from the CJEU in relation to the UK CFC rules (spoiler: the finance company exemption did not amount to state aid). Well done to our brilliant team who have been advising clients on this long-running saga. #fbdtax #tax #stateaid

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𝗙𝗶𝗻𝗮𝗻𝗰𝗲 𝗕𝗶𝗹𝗹 𝟮𝟬𝟮𝟰 - 𝗜𝗻𝗱𝗶𝗿𝗲𝗰𝘁 𝗧𝗮𝘅 𝗶𝗻𝘀𝗶𝗴𝗵𝘁𝘀 Read our insights on the VAT exemption for the management of EU funds, Excise Duty, VRT and more here: https://lnkd.in/ezS9QzbW

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In August 1920, the Dutch government presented a proposal for a tax treaty to their southern neighbors. This proposal was simple, principle based and similar to other early tax treaties being negotiated by European nations at the time. The initiative for the first comprehensive Double Taxation Agreement (DTA) between the countries stemmed from a Belgian appeal to resolve the issue of double taxation resulting from war profits taxes, mobilization tax, and other extraordinary taxes. More than hundred years later extraordinary taxes are on the rise again. What is different is that a comprehensive treaty network is in place, with treaty provisions that have grown more complex over time. Do they sufficiently address newly emerging tax issues? The Netherlands and Belgium are currently ratifying a revised tax treaty that will be the subject of a bilateral IFA Conference on 6 September 2024. Programme, speakers and registration are available at https://lnkd.in/gqxJPQVt. Join experts from government, practice, business and academia to explore the new convention between Belgium and the Netherlands and other international tax developments in the Low Countries. Registration is now open at a reduced rate for all IFA members! #IFAT #tax #internationaltax #taxtreaties #belastingverdrag #NederlandBelgië International Fiscal Association - Young IFA Network YIN - Young IFA Network (YIN Netherlands) - Women of IFA Network (WIN) - Bernard Peeters - IFA BELGIUM - Rhys Bane - Mahi Anastasiou - Linda Brosens - Wim Panis - Laurence Pinte - Frank Pötgens - Margriet Lukkien - Gijs Fibbe - Caroline Docclo - Rijkele Betten - Tim Wustenberghs

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🇪🇺 The EU is challenging Dutch tax laws to promote fairer cross-border investment practices and to create a level playing field for investors across the EU, particularly around dividend withholding taxes. Explore the potential impact of these changes in our latest blog post👇 #EUtax #DutchTaxLaw #InvestmentFairness #TaxNews

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Holding Regimes in a New Era - 2024 edition The 2024 edition of the Loyens & Loeff publication Holding Regimes in a New Era – Comparison of Tax and Non-Tax Aspects of Selected Countries provides a comprehensive overview of the most relevant tax aspects and certain non-tax aspects of 8 jurisdictions (The Netherlands, Luxembourg, Belgium, Ireland, Singapore, Spain, Switzerland and the United Kingdom). https://lnkd.in/eHGksycE

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Stay Ahead of International Tax Changes! Join Our International Tax Webinar!

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The Dutch Tax plan 2025 that was published today includes several proposals that are relevant for international companies. The key topics are discussed in below alert.

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A project we have been working on for the last two years or so: the establishment of our Mazars Financial Services Transfer Pricing Center of Excellence. Check out our website in the link and experience the value added services and solutions that this can bring to your organization #mazars #financialservices #banking #capitalmarkets #insurance #transferpricing #tax #london

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In the latest edition of Internationale Fiscale Actualiteit (4/2024), I have commented on the new transfer pricing documentation forms (Local File, Master File and CbC notification) that will be applicable as of 1 January 2025. Although at first sight the changes might seem limited, the additional guidance to these forms clarifies that important new information will need to be included in the Belgian Local File and Master File. In the Local File, the mandatory inclusion of available TP documentation is a significant change that should be taken into account by taxpayers. The increased Master File requirements regarding among others the description of the value chain, financial transactions and intangibles will also result in an increased compliance burden for multinationals, as they go beyond the OECD requirements.

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On Thursday 6 June, last, the Supreme Court of the Netherlands ruled in a number of cases that the legislation to calculate the taxable income for personal income tax purposes with respect to income from savings and investments (so-called Box 3 income) - just as the Supreme Court ruled in its so-called Christmas Judgment on 21 December 2021- violates both the prohibition of discrimination and the right to peaceful enjoyment of possessions as laid down in international treaties, in case the taxable notional or deemed return on savings and investments is higher than the actual return. In this article, Peter van Dijk, partner at BUREN, and Jitze de Beer, tax advisor at BUREN, discuss this ruling and the impact it will have on taxpayers. Read the full article by clicking on the following link: https://lnkd.in/gPB2AVWh #BUREN #legal #tax #notary #box3 #supremecourt

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