The Netherlands has published Decree no. 2023-11648 of 16 June 2023 in the Official Gazette, which provides explanations from the State Secretary for Finance in regard to various issues arising in the application of tax treaties. This includes issues concerning, among others, hybrid entities, corporate tax residence, dividends, interest, royalties, and entitlement to treaty benefits. The explanations include the interpretation of individual tax treaties, as well as the Decree on the Prevention of Double Taxation 2001 and relevant provisions in Dutch tax law. Some of the specific explanations are provided in relation to the following: Treatment of hybrid entities under...