The Federal Ministry of Finance has published a circular with comments on the consequences of a Supreme Tax Court decision from 2023 on hidden distributions and has in one part adjusted its earlier circular from 2017 regarding the tax accounting of pension commitments.
The two finance ministries have agreed on an automatic exchange of information on pensions paid to residents of their country under deduction of a withholding tax.
The finance ministry has agreed immediate application of the new Dutch tax treaty rule to the effect that civil service pensions paid by private pension funds are taxable in the country of payment.