You want your attention to be on growing and developing your company. You require (financial) advice about issues such as: whether to take care of your...
An accurate financial administration provides you with the information you need to take the right decisions. The big advantage of a digital financial administration is that it provides insight into your most important financial processes at any time, whether this is the invoices, salary payments or bank changes.
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Outsourced compliance services comprises the total financial compliance of your business, in accounting, financial reporting, payroll, legal and various tax reporting obligations. We can make sure you don’t have to worry.
On 26 October 2023, the Dutch House of Representative (Tweede Kamer) voted in favour of two amendments which will likely alter the current 30% tax ruling facility.
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Minimize risk, maximize predictability, and execution
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From the general terms and conditions to the legal strategy, these matters need to be watertight. This provides assurance, and therefore peace of mind and room for growth. We will be pro-active and pragmatic in thinking along with you. We always like to look ahead and go the extra mile.
Small company or large multinational: in any company your people are of the utmost importance for your business. Employment brings with it many issues in many areas and often has legal consequences. For big strategic, but also for more everyday questions about employment law, our lawyers are ready to help you out. Also for questions about international employment law. Do you have your own HR department? We’ll gladly assist them. We deliver bespoke services and are there when you need us.
Sustainability is more than a buzzword - it is the core of our legal advice towards sustainable success. From drafting sustainable contracts, integrating sustainable HR policies and ESG due diligence within our M&A practice to advising on ESG and other (national and international) legislation: we prefer to be pragmatic and proactive in helping your business.
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Starting in 2024, a new law for a global minimum profit tax for internationally operating companies will apply in the Netherlands: the 2024 Minimum Tax Act (Pillar 2).
Mirjam Zeldenrust
|3 min read|26 Jun 2023
HOT-proposal
HOT-proposal: a new Head Office Tax system in the EU
The European Commission proposed a new EU directive for micro, small, and medium-sized enterprises (SMEs) who operate cross-border through permanent establishments. This directive is called the Head Office Tax System for SMEs, also called the HOT-proposal. This directive is a set of rules designed to address the taxation challenges that arise when a company operates in more than one EU country.
Contents
One tax return
The HOT-proposal specifically addresses the situation where an SME has a head office in one EU member state and a permanent establishment in another EU member state. The advantage for SMEs that fall within the scope and meet all the conditions of the HOT-proposal, is that SMEs only have to deal with the tax authorities of the EU member state where the head office is located.
The head office serves as the "filing entity" for all permanent establishments, submitting a single tax return to the tax authority of the head office's EU member state. This process involves segregating the taxable income of the head office from that of its permanent establishments. The tax authority of the head office applies the tax rates applicable in the EU Member State where the permanent establishments are located. The tax authority of the head office will then collect the tax due and transfer the tax revenue to the relevant EU Member State of the permanent establishments.
Regarding audits, appeals, and dispute resolution, each EU Member State would retain the authority to audit permanent establishments within its own jurisdiction.
HOT-rules
To be able to apply the HOT-rules, the SME must meet certain conditions. Monique Pisters, Head of International Tax, explains the directive and the conditions in more detail in this video.
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Entry into force per 2026
The HOT proposal must now be agreed unanimously by the EU Member States. If adopted, the HOT-proposal rules should be implemented into Member States’ national law by 31 December 2025 and will apply from 1 January 2026.
Need advice or more information about the HOT-directive?
Companies within the scope of CSRD are required to report on material topics transparently. While the CSRD framework does not specifically mention ‘tax’, this does not mean that tax is irrelevant as a reportable entity-specific topic.
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