Quick Summary:  The Netherlands is comprised of 12 provinces with a capital at Amsterdam.  Following the dissolution of The Netherlands Antilles in 2010, the Caribbean Netherlands officially became part of The Netherlands. The Netherlands is a member of the North Atlantic Treaty Organization (NATO) and the European Union (EU).

Its corporate tax system provides for a full participation exemption on certain participations and several preferential tax regimes, including with respect to certain income derived from intellectual property.  The Netherlands introduced a special tax regime to encourage research and development, known as an innovation box, providing corporate income tax credits for certain profits derived from preferential innovations.

The Netherlands has a general anti-abuse rule (GAAR) under its longstanding fraus legis doctrine.  In 2019, the European Union Anti-Tax Avoidance Directive (EU ATAD 1) entered into effect in The Netherlands.  As part of its implementation, The Netherlands adopted a controlled foreign corporation (CFC) regime, as well as earnings stripping rules.  Effective in 2020, the Netherlands also adopted EU directive ‘ATAD II’, providing for hybrid mismatch rules. Read More