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Climbing Aletschhorn (4,190 meters), Bernese Highlands, August 2004



On July 14, 2015 the Dutch Ministry of Finance published a press release announcing that  the Netherlands and Germany signed a Memorandum of Understanding regarding the spontaneous exchange of information with respect to cross border tax rulings including rulings with respect to patent boxes.


The Dutch program of R & D tax incentives to stimulate Research &Development activities covers the whole R&D lifecycle, from development to the exploitation of successful R&D. The Government emphasizes the importance of R&D and its willingness to stimulate these activities. This is being underlined by the cooperative attitude of the different Government organizations that are involved with the implementation of the various R & D tax incentives. Dutch R&D tax incentives make a distinction between costs and investment-based R & D tax incentives on the one hand and a profit-based R & D tax incentive on the other hand (i.e. Dutch innovation box).


On February 12 we provided you with some comments on the new tax treaty between The Netherlands and China. The formal procedures in both countries have been completed. The new tax treaty, which will apply to income generated as of January 1, 2015, will enter info force on August 31, 2014.


On July 8 2014 the European Union’s Council of Economic and Finance Ministers (“ECOFIN”) formally adopted an amendment to the European Parent Subsidiary Directive (2011/96/EU) (the “Directive”) On the basis of this Directive EU member states are obliged to exempt from dividend withholding tax certain cross-border profit distributions within a group in order to prevent from double taxation on the profit received and that such groups are not put at a disadvantage compared to only domestically operating groups of companies. The Directive does not apply in case of capital gains.


The Dutch program of incentives to stimulate Research &Development activities covers the whole R&D lifecycle, from development to the exploitation of successful R&D. The Government emphasizes the importance of R&D and its willingness to stimulate these activities. This is being underlined by the cooperative attitude of the different Government organizations that are involved with the implementation of the various incentives. Dutch R&D incentives make a distinction between costs and investment-based incentives on the one hand and a profit-based incentive on the other hand (i.e. Dutch innovation box).


On 31 May 2013 a new tax treaty was signed between the Netherlands and the Republic of China. The new tax treaty contains certain updated and improved provisions to further promote investment and trading between both countries. China is already a large investor in the Netherlands and this new tax treaty will facilitate Chinese investments in the Netherlands further.
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