On 15 December 2021, the new Dutch coalition government (cabinet) published the Coalition Agreement 2021-2025, including its tax plans. For corporate tax, this includes adopting recommendations regarding the controlled foreign company (CFC) rules given by the Dutch Advisory Committee on the Taxation of Multinationals in their 2020 final report. The recommendations include applying the CFC rules to distributed profits, omitting downward transfer pricing adjustments to CFC income, and others. Further, the tax plans include confirmation of the implementation of Pillar II of the OECD global tax reform for a 15% global minimum tax. In the event that the CFC amendments...