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Dutch fiscal unity with non EU parent

Under current Dutch corporate income tax law Dutch sister companies cannot form a fiscal unity when the parent company has its residence outside the EU or European Economic Area. A recent ruling from the Dutch Court of Appeal allowed two Dutch sister companies with a common Israeli parent company to form a fiscal unity.

Dutch – Israeli tax treaty

The Dutch Court of Appeal ruled that the rejection of an appeal from the two Dutch sister companies to form a fiscal unity is in violation with the non-discrimination article in the tax treaty between the Netherlands and Israel. The non-discrimination article prevents that a Dutch subsidiary with an Israeli parent company is treated different from a Dutch subsidiary with a Dutch parent company.

Crowe Peak expects that the Dutch State Secretary of Finance will appeal to the ruling at the Dutch Supreme Court.

Crowe Peak
Olympisch Stadion 24-28 1076 DE Amsterdam, Nederland
088 2055 000 info@crowehorwath.nl