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New Dutch Decree on Allocation of Profits to Permanent Establishments

22 July 2022

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Approved Changes

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Netherlands

On 1 July 2022, the Netherlands published Decree No. 2022-0000143421 from the State Secretary for Finance, which provides guidance regarding the allocation of profits to permanent establishments. The new Decree entered into force on 2 July 2022, replacing Decree No. IFZ 2010/457M of 15 January 2011. The new Decree reflects developments in the area of profit allocation, including the results of the OECD BEPS project in particular, and incorporates the object exemption that was introduced into the Corporate Income Tax Act 1969 in 2012. Several editorial and reference changes have been made as well. Important changes in comparison to the...