Dutch corporation tax plans in 2012 Budget, cooperatives under attack?
By mistake the 2012 Budget was published yesterday afternoon. The bill will go to the parliament soon and enters into force at January 1, 2012. We will have to see how much of the current plan will be changed by the parliament.
The 2012 Budget introduces the following changes for the corporation and dividend tax:
1. limiting the interest deduction excessive holdings through the acquisition;
2. exemption for permanent establishments;
3. tax obligation of foundations and associations;
4. substantial interest in Dutch entities;
5. R & D deductions.
An unexpected change is about a substantial interest in Dutch entities. This includes the introduction of a dividend tax for memberships in cooperatives, which are (or as of today were?) used for one main purpose: to avoid the Dutch dividend withholding tax. Will this end the use of Dutch cooperative in international structures? Read more in section 4 and make up your mind.
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