- interest limitation rule;
- exit taxation rule;
- general anti-avoidance rule;
- Controlled-Foreign-Company rules; and
- the provisions on hybrid mismatches.
From January 1, 2019, the first EU Anti-Tax Avoidance Directive (2016/1164) (hereafter: ATAD1) is implemented by all EU Member States. A number of its provisions impact the field of (inter)national taxation. In the Netherlands we have seen the introduction of an earnings stripping measure and CFC legislation. In addition a number of provisions limiting the deduction of interest expenses have been abolished. This contribution intends to provide a summary. To serve its’ purpose we have also itemized a number of observations obtained in day-to-day to practice in relation to the earnings stripping provisions and its’ relation to the Dutch fiscal unity, ECJ legislation and transfer pricing.
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