Strategizing International Tax Best Practices – by Keith Brockman

The Dutch government has provided comments to the BEPS Guidelines, as they have generally been patient re: unilateral legislation that would represent non-conformity with the recently announced actions.  However, they would be ready to adopt tax incentives for Dutch taxpayers if there are unintended BEPS consequences that would weaken its attractive tax environment.  

PwC’ Tax Insights article provides details for this update:

http://www.pwc.com/us/en/tax-services/publications/insights/assets/pwc-dutch-government-responds-to-final-beps-reports.pdf

The article is refreshing re: BEPS conformity, including transparency, by the Dutch government.  The adoption of its innovation box regime as of 1/1/2017 will reflect the modified nexus approach of the BEPS Actions.

However, it is also interesting to note the measures it may take to retain its attractiveness for multinationals if there are adverse BEPS consequences.  This viewpoint is significant to watch, as other countries may adopt similar measures that will represent additional complexity and nonconformity around the world.  Additionally, each country will have its own view, in addition to unique incentives to protect its local tax base.

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