Update 2: Proposal Tax Plan 2024 BES Islands

Update 2: Proposal Tax Plan 2024 BES Islands

Last Friday, November 17, 2023, the memorandum in response to the report on the Proposal Tax Plan 2024 BES Islands from the Senate of the Dutch Parliament was published. This provides further explanation on the qualification of a participating interest as an asset with regard to the proposed change of the conditions of the establishment permit (in Dutch: ‘vestigingsplaatsbeschikking’) for holding companies.

A participating interest in an operating company established on Bonaire with an establishment permit will be considered a “good asset” for the asset test. Liquidities related to a cash dividend payment received from the local operating company are also considered “good assets”. As a result, holding companies will more easily comply with the prosposed change in conditions of the establishment permit and a mandatory relocation to the Netherlands for tax purposes will be prevented.