Dutch State Secretary of Finance Issues New Hybrid Mismatch Policy Decision 2026

The Netherlands published the Hybrid Mismatch Policy Decision 2026 from the State Secretary of Finance on 24 July 2026, updating and replacing the prior Hybrid Mismatch Policy Decision first issued in 2021 and updated in 2022. The key changes as summarized in the new policy decision include the following:

• New Section 2.3, which addresses the GILTI and NCTI regimes (U.S. tax regimes) regarding inclusion in taxation and double deduction;
• New Section 2.4, which adds rules regarding business …