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Bill to relax conditions for application of participation exemption, and to expand dividend withholding tax exemption

20 November 2009

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Proposed Changes

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Netherlands

In addition to the Tax plan for 2010 on 15 September 2009, a bill proposal concerning other fiscal measures for 2010 was published. The most important details are described below. Participation exemption (a) Lowed-taxed investment participations. Currently, the participation exemption does not apply to "low-taxed investment participations". Low-taxed investment participations are participations in a subsidiary that owns more than 50% portfolio investments and is not taxed in its state of residence at a rate of at least 10%, as determined in accordance with the Netherlands' standards. Under the proposal, the participation exemption would apply if a participation of at least...