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Step 1 – Does the EU Directive apply to the (MNE) group?
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Step 2 – Initial review of information to be provided in the top-up tax information return to be filed
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Step 3 – Taking stock of in-scope constituent entities
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Step 4 – Calculating the net qualifying income or loss of the constituent entities in a jurisdiction
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Step 5 – Computation of the adjusted covered taxes of the constituent entities in the jurisdiction
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Step 6 – Computation of the Effective Tax Rate for a jurisdiction
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Step 7 – Computation of the jurisdictional top-up tax for a fiscal year
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Step 8 – Application of the IIR, UTPR or the Domestic Top-Up Tax
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Step 9 – Filing the top-up tax information return and the accompanying notifications
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INTERESTING ARTICLES
Position of the Dutch tax authorities on the application of the withholding exemption of the Dutch dividend withholding tax Act in cases the dividend is not eligible for treaty benefits
The Inclusive Framework on BEPS released a consolidated version of the Commentary to the Global Anti-Base Erosion Model Rules
Memorandum of Understanding as concluded by the Dutch and German Ministries of Finance on their intend to continue their discussion on the tax consequence of teleworking by cross-border workers
The DAC9 Directive has been published in the Official Journal of the European Union
Protocol amending the existing DTA as concluded between the Kingdom of the Netherlands and the Federal Republic of Germany has been published in the Dutch State Gazette
Competent authority mutual agreement on the implementation of part VI of the multilateral convention to implement tax treaty related measures to prevent BEPS as concluded between the competent authorities of Belgium and The Netherlands
The Council of the European Union adopted the DAC9 Directive
The CJEU ruled in Case C-228/24, Nordcurrent group (The anti-abuse provision of the Parent-Subsidiary Directive)
The opinion of the Advocate General in the joined Cases C‑92/24 to C‑94/24, Banca Mediolanum, Banca Mediolanum – II and Banca Mediolanum – III (The interpretation of Article 4 of the Parent Subsidiary Directive)
The CJEU ruled in Case C-135/24, John Cockerill (The interpretation of Article 1, Paragraph 4 and Article 4 of the parent-subsidiary directive)
The European Commission calls on Spain to allow for a deduction of directly related expenses when calculating the withholding tax due over cross-border royalty payments
The European Commission decides to refer Spain to the CJEU due to discriminatory tax treatment of non-resident taxpayers
The UK notified Belarus and the Russian Federation about its intention to suspend the DTAs with those jurisdictions
The OECD released the OECD Secretary-General Tax Report to G20 leaders for the November 2024 meeting in Brazil