On 31 December 2018, the Netherlands published a regulation from the Secretary for Finance on amendments to certain implementing regulations in relation to tax changes for 2019. This includes, among other things, clarification on the meaning of substantial economic activity in relation to the new controlled foreign company (CFC) rules. In general, an exemption from the rules applies if the CFC undertakes substantial economic activity. In this respect, the exemption will apply if the following conditions are met: At least half of the total number of statutory and decision-making board members of the CFC reside in or are established in...