ey-global-tax-policy-outlook-for-2015

Netherlands
2.4 Tax policy outlook for 2015 — detail
Corporate income taxes
•
in order to comply with EU law. This follows a recent decision
unity regime contrary to EU law. A legislative proposal to
In anticipation of this proposal, an administrative decree is
an intermediate company in another EU or EEA (European
economic area) Member State should, subject to certain
unity regime.
• The Cabinet proposes to abolish the deductibility of foreign
a European Union (EU) institution are already non-deductible
for (corporate) income tax purposes.
•
capital instruments of insurance companies, which are
comparable with Tier 1 capital instruments of banks, as
loans. As a result, insurance companies will be able to
deduct the consideration for these types of instruments. It
may also result in the consideration’s recipient owing tax on
the consideration.
• Another proposal calls for the taxation status of public
enterprises to be amended. In the proposed legislation,
direct public enterprises will be liable to pay corporate
income tax to the extent they conduct a business. Indirect
public enterprises will be wholly or partially liable to pay
corporate income tax in accordance with the customary
legislative system, depending on the legal form chosen. It
should be noted that a number of exemptions are available
to public enterprises. The law is planned to come into force in
2015 and will be applicable as of 1 January 2016.
Taxes on wages and employment
•
36.25%. Effective 1 January 2015, this rate will be increased
to 36.5%. Although the rate will be increased, the amount of
the increase is less than anticipated, since the initial plan was
to increase the rate to 36.76% (after the one-off reduction
in 2014). The rates for the second, third and fourth brackets
will remain unchanged.
• The general tax credit is a deduction on PIT payable and
applies to all taxpayers. The tax credit will be reduced at an
accelerated rate for incomes in excess of EUR19,645.
• The working persons’ tax credit is a reduction on personal
income tax payable by taxpayers who enjoy income from
employment. The working persons’ tax credit is income
related. Measures have been made, resulting in a higher
working persons’ tax credit.
• In addition, the PIT rate for income derived from shares
forming part of a substantial shareholding (5% or more), also
referred to as “Box 2 income,” was reduced from 25% to 22%
in 2014. In 2015, that rate will be returned to 25%.
• Application of the work-related expenses scheme
(werkkostenregeling, “WKR”) will become compulsory as
from 1 January 2015, and the optional regime is set to be
abolished.
• A director and majority shareholder who holds a substantial
interest and performs work for his or her company is deemed
to have received a minimum salary from that company.
The Cabinet aims to reduce the difference in taxable pay
majority shareholder’s salary must equal at least 70% of the
salary of an employee under comparable circumstances.
With effect from 2015, this will be increased to 75%.
VAT, GST and sales taxes
• No major changes are expected.
The outlook for global tax policy in 2015 | 137