On December 30, 2019, the Dutch Ministry of Finance added Barbados and Turkmenistan to the list of low tax countries.
Blacklisted jurisdictions of countries where corporate tax rates are less than 9% are subject to the new rules on controlled foreign companies, which entered into force in the Netherlands on January 1, 2019 under the European Directive against tax evasion (ATAD). From 2021, interest and royalties paid in these jurisdictions will be subject to income tax at the general rate. Income tax rate in the Netherlands in 2021 is expected to be 21.7%.
In addition, from July 1, 2019, the Dutch tax authorities no longer issue tax opinions for companies that are blacklisted in jurisdictions.
According to information provided by the Ministry of Finance, Barbados was added to the blacklist, as from January 1, 2019, its corporate tax rate decreased under 9%. The Ministry of Finance also conducted an analysis of the tax burden of Turkmenistan, which showed that the real income tax rate is only 8% against the declared 20%.
Belize, Qatar, Kuwait and Saudi Arabia, on the contrary, were excluded from the black list after analysis showed that their corporate taxes increased higher than 9%.
To date, according to the changes, the Netherlands has a black list of 14 jurisdictions. These anti-tax evasion measures also apply to jurisdictions on the EU black list listing low tax countries.
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