Dutch Rule on Global Minimum Tax Payment From Entity Transfer

Companies transferring a low-taxed subsidiary are expected to calculate their global minimum tax liability on a pro-rata basis, according to the Dutch tax authority.

In the event of an internal transfer, one made within the same multinational group, the charge under the tax’s income inclusion rule “for each low-tax group entity in which the parent entity has a direct or indirect interest is calculated pro rata,” the Dutch Tax and Customs Administration said Monday.

The office made the statement in response to a question about how to calculate tax liability under the income inclusion rule when the ownership of a ...