Corporate - Significant developments

Last reviewed - 15 January 2021

The transition period for the following anti-avoidance rules will end as of 31 December 2021:

  • Dividend income and capital gains deriving from investments in foreign legal entities are not tax-exempt for income tax purposes anymore if more than 50% of the total income of the foreign legal entity consists of passive income and its taxable income is subject, directly or indirectly, to low taxation. This new rule is applicable - respectively the transition period ends - as of 1 January 2022 for participations established before 1 January 2019.