Dutch State Secretary of Finance Issues New Decree on Non-Deductible Interest Under Article 10a of the Corporate Tax Act

The Dutch State Secretary of Finance has issued Decree No. 2024-12473 of 30 May 2024, which was published in the Official Gazette on 14 June 2024. Decree No. 2024-12473 updates and replaces Decree No. BLKB2013/110M of 25 March 2013 on non-deductible interest. In particular, the decree contains the policy for Article 10a of the Corporate Tax Act 1969, which stipulates that interest on debts is not deductible in certain situations, including where the debt is related to:

• a profit distribution…