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Is your multinational company a reverse hybrid entity? Your subsidiaries will have to start paying taxes from 2022, depending on their legal structure:
- Corporate income tax (vennootschapsbelasting, vpb)
- Income tax (inkomstenbelasting)
- Dividend tax
- Withholding tax (bronbelasting)
- General Act pertaining to national taxes (AWR)
The tax duty applies to multinationals with more than 1 legal structure, based partly in the Netherlands and partly abroad, or founded in the Netherlands. For example, a Dutch private limited company (bv) with a number of limited partnerships in another country. These foreign legal structures have been exempt from paying taxes in the Netherlands until now, or have had to pay less. For tax purposes, these companies are reverse hybrid entities.
The measure aims to prevent tax avoidance and is part of the EU ATAD2, the Anti-Tax Avoidance Directive.
The measure does not apply to investment funds trading in securities.
- Multinational corporations consisting of more than 1 legal structure, that are founded or located in the Netherlands.
This change in regulation is expected to enter into effect on 1 January 2022.
Please note: The effective date of this measure is not yet final. Entry into force is subject to its passing through the upper and lower houses of parliament or proclamation of the Order in Council (Algemene Maatregel van Bestuur, AMvB) or ministerial decree and publication in the Staatsblad or Staatscourant (Government Gazette, in Dutch).