On 4 October 2013, an amendment to the Bill on other fiscal measures was submitted to parliament providing for a measure on international anti-avoidance. Unless otherwise indicated, the amendments would apply from 1 January 2014. The most important details of the amendment are summarized below. (a) Background Currently, cash-flow companies receiving and paying out interest or royalties to and from other countries only have to fulfil the substance requirements if: -   they want to obtain an advance tax ruling (ATR) or an advance pricing agreement (APA); and/or -   they want to be entitled to tax treaty benefits. In...