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GloBE Country Guide: The Netherlands

Summary

Status Enacted Law
LawOn December 27, 2023, the Dutch Official Gazette published the 2024 Tax Plan (which includes the Minimum Tax Act) to implement the EU Minimum Tax Directive.

On September 17, 2024, a draft law to amend the Minimum Tax Act was published. This includes a number of amendments to implement the OECD Administrative Guidance. On October 3, 2024, a further amendment to the draft law was published.
Effective DateDecember 31, 2023 (certain aspects of the September 2024 draft law are to apply from December 31, 2024)
IIRYes (2024)
UTPRYes (2025)
QDMTTYes (2024)
Filing DeadlinesStandard
Safe HarboursYes, the Transitional CbCR Safe Harbour, QDMTT Safe Harbour and the Transitional UTPR Safe Harbour

Contents
  1. Legislation
  2. General
  3. Differences to Model Rules
  4. Qualifying Domestic Minimum Top-Up Tax
  5. Administration and Filing
  6. Penalties

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