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US/Ukraine minerals deal: Digging into the detail
The United States and Ukraine governments have announced the signature of an agreement of a minerals deal for Ukraine.
Global | Publication | October 2017
The Dutch Government published its proposal of law for changes to the treatment of dividends paid by Dutch entities to their non-Dutch owners (the Proposal).
The Proposal aims to eliminate the difference between Dutch cooperatives and Dutch private companies (BVs) and public companies (NVs) and extends the exemption for dividend withholding tax to owners in tax treaty countries. The Proposal is generally in line with the Government’s internet consultation issued on 16 May 2017. This note discusses the main aspects of the Proposal, which should become effective as from 1 January 2018.
The Proposal contains three main changes to the current Dutch dividend withholding tax regime:
The Proposal is largely in line with earlier publications, save for certain specific new insights (e.g. hybrids). It has both a negative effect, including a 15% dividend tax on distributions made by (passive) holding cooperatives to members in a non-treaty country, as well as positive effects, i.e. an exemption from dividend tax in non-abusive business structures in treaty situations for cooperatives, BVs and NVs alike.
We recommend reviewing existing structures that make use of cooperatives for the holding of participations in light of this Proposal. This Proposal may also allow you to simplify your corporate structures or otherwise limit a Dutch dividend withholding tax exposure. We are obviously more than happy to assist you in reviewing your structures to ensure their future effectiveness.
Publication
The United States and Ukraine governments have announced the signature of an agreement of a minerals deal for Ukraine.
Publication
On 15 April 2025, Ofgem approved the National Energy System Operator’s (NESO) Target Model Option 4 (TMO4+) package of reforms.
Publication
In mid-March 2025, Cognia Law and Norton Rose Fulbright’s Legal Operations Consulting team co-hosted a second roundtable event that brought together senior leaders, including GCs, COO and head of legal operations, from across the legal industry to discuss how to drive meaningful change within the legal ecosystem.
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