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Key Insights on New Dutch VAT Rules for Holding Companies Effective July 2025

  • New Dutch VAT rules for holding companies and share transactions will take effect on 1 July 2025.
  • These changes may impact businesses with Dutch holding companies or investment vehicles, including brands, tech companies, life sciences, financial institutions, and private equity firms.
  • VAT on costs that were previously reclaimable may no longer be reclaimable, potentially resulting in new tax costs.
  • The changes involve the withdrawal of two Dutch VAT decrees: the Holding Resolution from 1991 and the Share Sale Decree from 2004.
  • The Holding Resolution allowed VAT reclaim under favorable conditions, but new rules align with stricter EU VAT case-law, defining specific scenarios for VAT reclaim.
  • Passive holding companies can still be included in a Dutch VAT group under certain conditions, with an expansion to intermediate holdings.
  • The Share Sale Decree previously allowed favorable VAT treatment for share transaction costs, but a new framework will determine VAT recovery rights.

Source: twobirds.com

Note that this post was (partially) written with the help of AI. It is always useful to review the original source material, and where needed to obtain (local) advice from a specialist.

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