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20-01-2018

Dutch Tax Services | Additional substance requirements

The Dutch Dividend Withholding Tax Act and Corporate Income Tax have been amended as per 1 January 2018. This also resulted to an update of the decree with guidance on the substance required for a foreign intermediary holding company with an interest of five percent or more ('parent company'). Effectively as of 1 April 2018, the following two Dutch substance requirements are added:
- the parent company incurs minimal wage costs related to holding activities in an amount of EUR 100,000
- the parent company has at its country of residence an equipped office to its disposal which is also actually used for holding purposes.

The country of living index is multiplied by the minimal required wage costs. Thus making the costs for example EUR 90,000 for Cyprus and EUR 100,000 for Luxembourg.



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