|Corporate income tax|
The Dutch corporate income tax (“DCIT”) rate currently (2011) stands at 25% calculated over profits in excess of EUR 200,000 (lower profits are taxed against 20%). However, practice has shown the effective DCIT rate can be (significantly) lowered by manipulating the taxable base by skilled use of the tools as provided by our DCIT Act 1969 (revised in 2007).
The actions taken by your business can affect your DCIT position. We therefore recommend to carefully lay out the tax consequences beforehand, including the optimal tax (exit) route in order to attain your goals. Voorbij & Partners can safely and beneficially navigate you through the rules and regulations of the DCIT.
Through the years this has become not a superfluous luxury, given the complexity of the DCIT Act 1969. This Act is subject to continuous amendments and currently has many special rules, regulations, decrees, anti-abuse measures and exception rules, amongst others regarding:
· Transfer pricing;
· The participation exemption;
· The fiscal unity;
· Mergers, acquisitions and spin-offs;
· Deductible interest;
· Thin capitalisation;
· Deductibility of losses; etc. etc.
Nevertheless, the sheer multitude of rules, regulations and case law provide for a number of possibilities for optimal tax planning and application of exemptions and deductibility options. The ever-growing complexity of rules and case law may also risk forgoing any tax saving opportunities or leading up to double taxation. By timely consulting our advisers you have assurance each planned action and legal structure will be implemented in a tax beneficial fashion, focussing on risk control and tax saving.