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Netherlands to Request Removal from Brazil's Grey List

03 February 2016

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Proposed Changes

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Netherlands-Brazil

According to a letter dated 25 January 2016 from the Dutch State Secretary for Finance Eric Wiebes to parliament, Wiebes stated that he will formally request the removal of the Netherland's from Brazil's grey list. The Netherland's was effectively added to Brazil's grey list through Executive Declaratory Act No. 3/2015, which repealed the exclusion of Dutch holding companies without sufficient economic substance. A number of tax issues are triggered by the inclusion in the list, including the application of Brazil's thin capitalization and transfer pricing rules, whether the parties are related or not.