Memoranda

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Laws
Capital duty (Subscribers)Description of Dutch capital duty
Corporate income tax (Subscribers)Description of Dutch corporate income tax
Dividend withholding tax (Subscribers)Description of Dutch dividend withholding tax
Real estate transfer tax (Subscribers)Description of Dutch real estate transfer tax
Surtax (Subscribers)Description of what this unfortunate tax is
General Topics
Anti-abuse lawsDescription of various anti-abuse rules in Dutch law
Asset mergersTax treatment of asset mergers
Consolidated Tax Groups - asof 1/1/2003 (Subscribers)Description of the new Dutch "fiscal unity" rules
Consolidated Tax Groups - until 1/1/2003 (Subscribers)Description of the old Dutch "fiscal unity" rules
ConvertiblesDescription of how convertibles are treated under Dutch law
Corporate income tax 2007Proposed amendments for 2007 tax reform
Corporate tax proposals for 07Dutchtax.net's contribution to the open forum discussion on
Debt vs EquityTreatment of debt and equity under Dutch law
Dividendstripping (Subscribers)Description of this counter intuitive anti-abuse measure
Employee stock optionsThe tax treatment of ESOPs for Dutch corporate taxpayers
Functionally currency regimeDescription of Dutch rules on functional currency
General Dutch tax issues (Subscribers)Description of general issues under Dutch law
Inbound investments (Subscribers)Dutch tax consequences for corporate inbound investors
Interest deduction limitations (Subscribers)Summary of the many limitations on the deduction of interest
Law nr. 26.854Parliamentary history 2003 tax consolidated group regime
Law nr. 28.487Parliamentary history hybrid loans; extension earn out rules
Law nr. 28.608Parl. history on part. exempt. in EU co's and tax consolidation
Law nr. 29.686Conversion debt to equity, writing down and deduction acquisition costs participations
Legal demergersDescription of tax treatment of legal demergers
Legal mergersTreatment of legal mergers under Dutch tax law
Limited partnerships (Subscribers)Description of treatment of limited partnerships under Dutch law
Loss compensation (Subscribers)Rules on loss compensation under Dutch law
MergersDescription of general tax consequences of mergers
Non-resident hybrid entitiesDescription of qualification of non-resident entities
Non-resident taxpayers (Subscribers)Summary of the various ways non-residents can be subject to Dutch CIT
Outbound investment (Subscribers)Description of tax consequences of outbound investment
Participation exemption and hybrid loans (Subscribers)Using Hybrid Loans as an alternative to the participation exemption
Participation exemption: anti-abuseAnti-abuse rules under participation exemption regime
Participation exemption: ConditionsConditions applying under the participation exemption regime
Participation exemption: costs & lossesTreatment of costs and losses under the participation exemption regime
Participation exemption: exemptionsDescriptions of income and gains exempt under the participation exemption
Participation exemptions (Subscribers)Description of this measure for the prevention of double taxation within groups
Prevention of double taxation (Subscribers)Description of the Dutch unilateral rules
Profit sharing loans (Subscribers)Description of this interesting Dutch legislation
Residents vs non-residentsDescription of differences between resident and non-resident corporate taxpayers
Rulings (Subscribers)Description of current Dutch ruling policy
SecuritisationsDescription of Dutch decree on securitisations, loss absorption and profit sharing loa
Share mergersTax consequences of share mergers
Special Knowledge Groups (Subscribers)Description of Dutch Ministry's Special Knowledge Groups
Tax rates 2003Overview of rates of various taxes for 2003
Tax rates 2004Overview of rates of various taxes for 2004
Tax rates 2005Overview of rates of various taxes for 2005
Tax rates 2006Overview of rates of various taxes for 2006
Thin capitalisation (Subscribers)Description of the Dutch thin capitalisation rules
EU Law
Cadbury SchweppesDiscussion of the Cadbury Schweppes Case before the EU Court of Justice
Florian WallentinDiscussion of the Florian Wallentin Case before the EU Court of Justice
Fokus BankDiscussion of the Fokus Bank Case before the EFTA Court
Marks & SpencerDiscussion of the Advocate General's opinion in the Marks & Spencer Case before th

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