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A consultation has been launched proposing to lower the initial notification threshold of a ‘substantial’ shareholding, voting rights or gross short position from 3% to 2% in the issued capital of a qualifying listed company. The existing thresholds (including the 3% threshold) remain in place. According to the explanatory notes, the introduction of the additional notification threshold should - amongst others - enhance the knowledge about (changes in) voting power and capital interest when making investment decisions. It is envisaged that this new legislation enters into force on 1 January 2021.
On 14 June 2019, the Dutch State Secretary of Finance (State Secretary) announced he will propose legislation amending the rules for foreign intermediate holding companies with ‘relevant substance’ that qualify for the Dutch dividend withholding tax (DWT) exemption. The proposal entails the possibility of counterproof for the Dutch Tax Authorities (DTA) that, even if the relevant substance criteria are met, a structure is abusive and the DWT exemption does not apply. It should enter into force on 1 January 2020 and would similarly apply to the Dutch non-resident corporate tax rules. Existing rulings will continue to be valid until explicitly notified differently by the DTA.