On Tuesday 21 September 2021 (Budget Day), The Dutch Minister of Finance revealed the Tax Plan 2022 in which several tax measures were announced. The Tax Plan 2022 will be discussed in the Dutch Parliament in the coming period. The proposals are subject to approval by the Dutch Parliament and therefore changes may occur or proposals may even not be implemented at all.
Please note that the Netherlands are actually in a cabinet formation mode. As a result the measures in the Tax Plan 2022 are limited in comparison with previous years. Nevertheless, some measures may still affect your business or personal situation.
In the attachment you can find our Budget Day Special 2021, in which we have outlined the most important measures of the Tax Plan 2022.
Below you can find a selection of the most important topics:
- Reverse hybrid entities - like a “besloten-CV”- will become subject to corporate income tax (CIT) as of 1 January 2022.
- Specific downward adjustments resulting from the application of the arm’s-length-principle will no longer be taken into account for CIT-purposes.
- As of 1 January 2022 dividend withholding tax may only be credited against payable CIT and can no longer result in a refund.
- Considerable increase in environmental investment tax deduction rates.
- The lower tax bracket (tax rate 15%) is extended from € 245.000 to € 395.000. Profits exceeding this tax bracket are taxable at 25% (Tax Plan 2021 unmodified).
- New loss utilization rules apply as of 1 January 2022 (Tax Plan 2021 unmodified).
- Wider scope definition of ‘permanent establishment’ with respect to withholding tax on interest and royalties.
- More flexibility in pay roll taxation in relation to employee-share-option-plans.
If you have any questions regarding this email or the Budget Day Special 2021, please do not hesitate to contact your regular contact person at Dirkzwager Legal & Tax.