GloBE Country Guide: The Netherlands

Summary

Status	Enacted Law
Law	On 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. This was approved by Parliament on December 17, 2024. The Dutch Minimum Tax Executive Decree 2024 was published in the Government Gazette on December 23, 2024.
Effective Date	December 31, 2023 (certain aspects of the December 2024 amendment law are to apply from December 31, 2024)
IIR	Yes (2024)
UTPR	Yes (2025)
QDMTT	Yes (2024)
Filing Deadlines	Standard
Safe Harbours	Yes, the Transitional CbCR Safe Harbour, QDMTT Safe Harbour and the Transitional UTPR Safe Harbour

Legislation
General
Differences to Model Rules
Qualifying Domestic Minimum Top-Up Tax
Administration and Filing
Penalties

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Lee Hadnum

Lee is a qualified Chartered Accountant and a former Senior Tax Analyst at Bloomberg Tax. Lee began his career in Ernst & Young's Entrepreneurial Services department and has 20 years of international tax planning experience.

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