The Netherlands legislative proposal to transpose Pillar Two into the Dutch company tax system, titled ‘Minimum Tax Act 2024 (Pillar Two),’ was submitted to the Dutch Parliament on May 31.
The Netherlands is the first country within the European Union to release its domestic Pillar Two legislation. By doing so, the Netherlands takes the next step in implementing Pillar Two, effective December 31, 2023.
The legislative proposal is based on the text of the European Union Directive dated 14 December 2022, introduces a Qualified Domestic Minimum Top-up Tax (QDMT), and contains the Safe Harbor rules. The legislative proposal is structured as a separate tax law that is not intended to be embedded into the existing Dutch Corporate Income Tax Code.