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On 29 March 2021 the Dutch Ministry of Finance published a consultation document which includes proposed amendments to the Dutch qualification rules for Dutch and foreign entities. The consultation period ends on 26 April 2021.

The aim of the proposal is to reduce the number of hybrid mismatches in an international context. In particular, the proposed rules should result in less hybrid mismatches due to the asymmetric qualification of entities. Discrepancies in the fiscal qualification of entities between countries may result in income either being taxed twice (i.e. at the level of the entity and at the level of its participants) or not at all.

It is envisaged that a legislative proposal will be published after the consultation period and that this proposal will be part of the 2022 Budget Day tax plan. The amendments are proposed to enter into force on 1 January 2022.