Netherlands Decree on Reorganizations and the Amended Innovation Box Regime

On 15 September 2017, the Netherlands Ministry of Finance published Decree No. 2017-167217 concerning business mergers, legal divisions, and legal mergers in relation to amendments to the innovation (IP) box regime that were made as part of the 2017 tax plan ({News-2016-12-29/A/3-previous coverage}). Changes to the innovation box were made to bring it in line with the modified nexus approach of BEPS Action 5. The Decree provides, in general, that where the innovation box is used, an exempt d…