On 14 April 2013, the Dutch tax administration published an updated annex to Decree No. CPP/2009/519M of 11 December 2009, on the classification of foreign entities (Decree). The Decree lists the criteria used to decide whether a foreign entity must be classified as a transparent or non-transparent entity. This distinction is particularly relevant for the tax treatment of taxpayers holding an interest in a foreign entity. Corporations are always treated as a non-transparent entity, while partnerships are always treated as a transparent entity, which means that the profits are directly attributed to the underlying participants. For the classification, the laws...