Foreign tax liability

The Dutch cabinet in its 2014 Tax Plan, which it published in mid-September last year, included an announcement to the effect that the optional regime for foreign taxpayers with effect from the first of January 2015 was to be replaced by a regime specifically geared to qualifying foreign taxpayers. 

This change would have resulted in taxpayers who emigrated or immigrated while a particular calendar year was under way and who while residing abroad did not qualify for foreign tax liability being denied tax relief for the relevant (calendar) year, albeit that they would be compensated by being granted a tax credit in proportionality with the duration of their domestic or qualifying foreign tax liability.

As the change in question will not be realisable until the first of January 2016, it has been decided by way of a transitional arrangement that the tax credit is to be awarded in its entirety throughout 2015 to all those who have either domestic or qualifying foreign tax liability for part of the year.