author_orbitax
Orbitax

Share This Article

Dutch Ministry of Finance Proposing Amendment to Entity Classification to Address Hybrid Mismatch Issues

01 April 2021

|

Proposed Changes

|

Netherlands

The Dutch Ministry of Finance is reportedly finalizing a legislative proposal that would amend the country's current entity classification rules in order to address certain hybrid mismatch issues. In particular, this includes changing the treatment of limited partnerships (commanditaire vennootschap - CV) so that CVs are always treated as transparent instead of the current rules that allow treatment as transparent or non-transparent. Under this proposed change, CVs currently treated as non-transparent will be deemed to realize their assets when becoming transparent, which will be a tax triggering moment. Given that this may result in tax becoming due without cash being...