Overview: Reshaping the Dutch Corporate Income Tax System

Abstract

Globally, the Netherlands is known for its (attractive) corporate income tax system. Examples are, but not limited to, the fiscal unity regime with full tax consolidation for group companies and the full participation exemption for capital gains and dividends from qualifying domestic and foreign participations. 

However, mainly due to the international BEPS project and measures of the European Commisssion, the Dutch corporate income tax system has been under pressure lately. There has been criticsm, both nationally and internationally, arguing that the Dutch tax system leads to aggressive tax planning and that it is a tax heaven. The Netherlands wants to get rid of this reputation without endangering the attractive Dutch competitive position for foreign investments. This article provides an overview of the measures taken by the Dutch government that influence the Dutch corporate income tax system.