There has recently been a great deal of debate about “letter-box companies” being used to create improper tax advantages (such as reducing foreign withholding taxes) and this debate has drawn considerable attention in the Netherlands in particular (including in Parliament).
The BEPS report presented by the OECD is one of the drivers of the debate. It focuses on combatting tax avoidance and proposes fifteen actions. A key pillar is the substance of companies. Substance requirements have received increased attention from both the Netherlands and the OECD, leading to some tightening of national and international substance regulations.
