Dutch Tax Authority Pillar 2 Knowledge Group Positions

The Dutch Tax Authority's Pillar 2 Knowledge Group has issued several positions regarding the application of the Minimum Tax Act 2024. Recent positions from the Pillar 2 Knowledge Group clarify the application of the Minimum Tax Act 2024 regarding:

• The requirements for a "treaty permanent establishment," specifying that the source state must tax income on a net basis in a manner comparable to domestic entities - KG:911:2026:1;
• The technical definition of a "joint venture," requiring the use…