The New Dutch ‘Base Exemption Regime’ and the Spirit of the Internal Market

As of 1 January 2012, the Dutch corporate income tax (‘CIT’) system provides for international juridical double tax relief (‘DTR’) under a mechanism referred to in Dutch tax practice as the ‘base exemption for foreign business profits’1 (author’s translation).2 The newly introduced DTR mechanism replaces the Dutch-style ‘tax exemption with progression method’3 in the area of corporate taxation regarding proceeds derived from foreign-source business activities. The rationale for this legislative shift, according to the Dutch tax legislator, is to arrive at an augmented level of converged tax tr... Mehr ...