The Dutch Ministry of Finance has announced the submission of a bill to the House of Representatives for the implementation of the hybrid mismatch measures of the EU Anti-Tax Avoidance Directive as amended (ATAD2), including deduction/non-inclusion mismatches and multiple deduction mismatch. As when the bill was consulted on, the announcement notes in particular, the well-known Dutch CV / BV structure, which has allowed U.S. companies to defer taxation due to the differing Dutch and U.S. treatment of the structure. With the implementation of the ATAD2 measures, the Dutch government will end the attractiveness of this structure. Click the following link...