Netherlands: Changes to the corporate income tax consolidation regime
The Dutch parliament has approved the proposal to change the Dutch corporate income tax consolidation regime (fiscal unity). The new legislation stipulates that for the application of the following provisions, a fiscal unity would be deemed not to exist:
- Anti-base erosion rules
- Excessive participation debt rules
- Certain specific elements of the participation exemption rules
- A specific reduction of dividend withholding tax in the case of an immediate redistribution
These changes will take retroactive effect from 1 January 2018.