Budget Day 2018 The tax consequences of the Dutch Tax Plan by tax type - September 18, 2018 | EY.nl/Prinsjesdag
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Budget Day 2018 The tax consequences of the Dutch Tax Plan by tax type September 18, 2018 | EY.nl/Prinsjesdag
Introduction
It is almost as much a tradition as the Budget Day itself: the Budget Day mailing from EY. This year
we are again informing you about the fiscal measures that the cabinet has proposed on the Budget
Day. The package of tax measures mainly consists of the plans that the cabinet already announced
in the coalition agreement "Confidence in the future".
The decrease of labor costs, prevention of tax avoidance and evasion and maintenance of a good
Dutch business climate are the priorities of the cabinet this year. In addition, the parliament is
focused on a greener and more workable tax system.
The economy is currently in full force and employment has increased in recent years. The cabinet
believes that the Dutch population must be able to feel the positive effects hereof in their wallets.
The costs of labor will therefore be reduced.
According to the cabinet, the purchasing power of all groups, particularly of employees with a
medium wage, will increase as a result of the combination of measures included in this Tax Plan
2019 package. The cabinet states that the purchasing power of 96% of the households will improve
and that the (average) purchasing power of all households will be +1.6%.
The cabinet partially funds the reduction of the labor costs through the increase of other taxes and
the reduction of the rate against which certain deductions are taken into account. This applies to,
for example, the mortgage interest tax relief and the allowance for entrepreneurs.
The cabinet shifts the labor costs to costs of consumption by increasing the reduced VAT rate from
6% to 9%. As a result, groceries and consumption will become more expensive. The decrease of the
corporate income tax rate results in the increase of the box 2 tax rate. The parliament indicates that,
on balance, almost all entrepreneurs will benefit.
This year, the Tax Plan package consists of seven legislative proposals.
Tax Plan 2019
Legislative proposal Act withholding tax 2020
Legislative proposal fiscal greening measures 2019
Legislative proposal Other fiscal measures 2019
Legislative proposal Act implementation article 1 electronic commerce directive
The Legislative proposal Act modernization small business scheme
The Legislative proposal Act adjustment gambling tax for sports betting
In the legislative proposal Act withholding tax 2020, a number of coherent measures are included.
For example, the respective legislative proposal includes the introduction of the source tax on
dividend payments to low-tax jurisdictions and in abuse situations, the abolishment of the dividend
withholding tax and the reduction of the corporate income tax rate. Furthermore, measures that
broaden the taxable base are proposed in the corporate income tax, such as a limitation of the
depreciation of buildings and the limitation of the offsetting of losses.
In addition to the tax plan 2019 package, the legislative proposal Act implementation of the first EU
anti-tax avoidance directive was published on Budget Day. This legislative proposal contains
measures to implement the European Anti-Tax Avoidance Directive (ATAD1). The cabinet indicates
that this factually means that the rule for the limitation of interest deduction ("earnings stripping")
and the rule for the so-called controlled foreign entities, abbreviated as CFC, will be introduced. The
current exit tax is also amended. According to the cabinet, the mandatory implementation of a
general anti-abuse provision is not required as the Netherlands already has a general anti-abuse
provision through the fraus legis doctrine.
The legislative proposals are not yet final. During the parliamentary proceedings, changes may still
arise. We are of course closely monitoring the developments regarding the plans of the cabinet. We
1
will keep you informed of all relevant developments through our website EY.nl/Prinsjesdag and
social media.
Best regards,
Jeroen Davidson
Managing Partner EY Tax
2Content 1. Personal income tax ....................................................................................................... 4 1.1 Rate box 1 Personal Income Tax (work and home) ....................................................... 4 1.2 Increase tax rate box 2 of the Personal income tax (substantial shareholding) ................ 4 1.3 Limitation of loss setoff in box 2 of the Personal income tax......................................... 4 1.4 Increase of the tax credits ......................................................................................... 4 1.5 Scaling back of tax allowance .................................................................................... 4 1.6 Scaling back of mortgage interest deduction............................................................... 5 1.7 Lowering the notional rental value of residences ......................................................... 5 1.8 Investment schemes continued until 2024; energy investment allowance reduced to 45% 5 1.9 Extension validity of exemption for foster parent compensation ................................... 5 1.10 Levying of taxes if director and major shareholder has a large current account debt....... 5 2. Payroll tax..................................................................................................................... 6 2.1 Changes to the 30%-scheme ..................................................................................... 6 2.2 Amendments bicycle scheme 2020 ........................................................................... 6 2.3 Tax-free volunteer allowance ..................................................................................... 6 3. Corporate tax ................................................................................................................ 7 3.1 Determination reversal innovation box benefit amended .............................................. 7 3.2 Limitation of depreciation of building in own use ......................................................... 7 3.3 Fiscal investment institution may no longer directly invest in Dutch real estate .............. 7 3.4 Reduction of the corporate income tax rate ................................................................ 7 3.5 Limitation of loss setoff in the corporate income tax .................................................... 7 3.6 European Anti-Tax Avoidance Directive ...................................................................... 8 3.7 Implementation of earnings stripping measure ........................................................... 8 3.8 Implementation of Controlled Foreign Company (CFC) rule ........................................... 8 3.9 Amendment exit taxation .......................................................................................... 8 3.10 Abolishment interest deduction limitation rules and limitation rules for offsetting of losses holding and financing companies ........................................................................................... 8 3.11 Abolishment deduction tier 1 capital banks and insurers .............................................. 9 4. Dividend tax and witholding tax ..................................................................................... 10 4.1 Abolishment dividend withholding tax and introduction source tax in abuse situations .. 10 5. Turnover tax (VAT)....................................................................................................... 11 5.1 Increase of the reduced VAT rate from 6% to 9% ........................................................ 11 5.2 Expansion of the sports exemption for VAT .............................................................. 11 5.3 Simplification of VAT rules for electronic services ..................................................... 11 5.4 Simplification of the VAT small business scheme ....................................................... 11 6. Environmental taxes .................................................................................................... 12 6.1 Greening tax measures ........................................................................................... 12 6.2 Amendments to the energy tax rates ....................................................................... 12 6.3 Amendments to the waste tax ................................................................................. 12 7. Landlord levy .............................................................................................................. 13 7.1 Tax reduction in the landlord tax .............................................................................. 13 8. State Taxes Act ............................................................................................................ 14 8.1 Protective tax assessment regarding pension upon emigration ................................... 14 8.2 Amendment tax interest scheme for Personal income tax and inheritance tax .............. 14 8.3 Tackling recovery structures ................................................................................... 14 8.4 The term violator for tax purposes ........................................................................... 14 8.5 Processing of vehicle registration details .................................................................. 15 9. Gambling tax ............................................................................................................... 16 9.1 Amendment gambling tax for sports betting ............................................................. 16 10. Contact....................................................................................................................... 17 3
1. Personal income tax
1.1 Rate box 1 Personal Income Tax (work and home)
The rate of box 1 of the Personal Income Tax (including the social security premiums) will be as
follows in 2019:
Taxable income To Income Tax Social Security Total
from Premiums
- €20,384 9.00% 27.65% 36.65%
€20,384 €34,300 10.45% 27.65% 38.10%
€34,300 €68,507 38.10% - 38.10%
€68,507 - 51.75% - 51.75%
1.2 Increase tax rate box 2 of the Personal income tax (substantial
shareholding)
A director and major shareholder (in Dutch ‘dga’) with a substantial shareholding in his BV
[company] must declare income from his BV in box 2 of the Personal income tax. In short, a
substantial shareholding exists if the share interest of the dga exceeds 5%. The tax rate of box 2 will
be increased as of 2020.
1.3 Limitation of loss setoff in box 2 of the Personal income tax
The setoff of losses in box 2 of the Personal income tax (losses from a substantial shareholding) is
limited to six years.
Losses in box 2 can be offset with
income from a substantial shareholding in the previous year (carry back);
income from a substantial shareholding within the next nine years (carry forward).
1.4 Increase of the tax credits
The tax credits will be gradually increased.
To provide families with lower income also the tax benefits, the government proposes to increase
the maximum general tax credit to €2,477 in 2019, €2,642 in 2020 and €2,753 in 2021. The
maximum for the employed person’s tax credit will also be increased from €3,399 in 2019 to
€3,941 in 2021. The maximum income-related combination tax credit (‘IACK’) remains the same,
but is already received by an individual with a lower income.
1.5 Scaling back of tax allowance
As per 1 January 2019, tax allowance is deductible at a rate of 51.75% in the highest bracket of the
Personal income tax. However, as per 1 January 2020 a large number of tax allowances will be
scaled back.
4In 2020, the deductibility in the highest bracket will only be 46%, and this will annually be further
decreased with 3%. As per 1 January 2023, the tax allowances will only be deductible at the rate of
the first bracket (37.05%).
1.6 Scaling back of mortgage interest deduction
The mortgage interest deduction in the highest bracket of the Personal income tax is reduced with
0.5% as of 1 January 2014. This is continued in 2019 resulting in a deductibility of 49% in 2019 in
the highest bracket. As of 2020 the scaling back is accelerated resulting in annual reduction of 3%.
1.7 Lowering the notional rental value of residences
Owners of a residence must report the notional rental value of residences (in Dutch
‘eigenwoningforfait’). This value will be gradually decreased. For residences with a real estate value
(in Dutch ‘WOZ-value’) between € 75,000 and € 1,060,000 (amount in 2018), the notional rental
value will gradually decrease from 0.70% to the expected percentage of 0.45% in 2023.
1.8 Investment schemes continued until 2024; energy investment
allowance reduced to 45%
The sunset clause of the energy investment allowance (in Dutch: ‘energie-investeringsaftrek’ or EIA),
the environmental investment allowance (in Dutch: ‘milieu-investeringsaftrek’ or MIA) and the
arbitrary depreciation for environmental investments (in Dutch: ‘willekeurige afschrijving milieu-
investeringen’ or VAMIL) has been extended until 1 January 2024. The regulations are as such
continued for the upcoming five years. In addition, the EIA percentage will be reduced from 54.4%
to 45% as of 1 January 2019.
1.9 Extension validity of exemption for foster parent compensation
Those who take care of a foster child, may receive a foster parent compensation. From a tax
perspective, the foster parent compensation is not considered as income and does not affect the
amount of the healthcare allowance, housing allowance, benefit or personal budget (in Dutch:
‘persoonsgebonden budget’ or PGB). Pursuant to the sunset provision included in the law, the
exemption for foster compensations will lapse per 1 January 2019. However, the cabinet proposes
to, in any event, have the exemption for foster compensations to continue during 2019.
1.10 Levying of taxes if director and major shareholder has a large current
account debt
It is noteworthy that it is stated in the Budget Memorandum that the cabinet is going to discourage
tax deferral by taxing the debt ratio between the director and major shareholder (‘dga’, in Dutch
‘directeur-grootaandeelhouder’) and his own private limited liability company (‘BV’) in box 2 of the
Personal income tax to the extent it exceeds € 500,000. However, no reference is made to this in
the published legislative proposals. It is said that these will be included in next years Tax Plan for
2020.
52. Payroll tax
2.1 Changes to the 30%-scheme
The period during which a free allowance may be granted for extraterritorial expenses (in Dutch:
‘extraterritoriale kosten’ or ET) incurred by expats (“incoming employees") is shortened by three
years from eight to five years. This applies for both the fixed free allowance of 30% of the salary
and the free allowance of the actual ET expenses. Existing cases are also affected by this. As no
grandfathering rules are proposed, the 30%-scheme may already terminate in certain cases as per
1 January 2019 or during the course of 2019.
2.2 Amendments bicycle scheme 2020
The cabinet wants to promote employers to put a company bicycle at the disposal of their
employees (no transfer of ownership to the employee). The cabinet would in this respect like to
eliminate the tax obstacle by a simplification of the valuation of the private benefit of the company
bicycle.
2.3 Tax-free volunteer allowance
Under certain conditions, a tax free allowance of maximum €150 per month and €1,500 per year
may be paid to volunteers in 2018. As of 1 January 2019, these amounts are increased to €170
and €1,700.
63. Corporate tax
3.1 Determination reversal innovation box benefit amended
For purposes of the reversal of the benefit from the application of the innovation box, the exact
amount that was previously not taxed will as of now be used instead of a fraction that is based on
the corporate income tax rate.
3.2 Limitation of depreciation of building in own use
In the corporate income tax, the possibility to depreciate a building which is used by the taxpayer
itself (or an affiliated company), will be limited per 1 January 2019. As such, buildings can only be
depreciated up to the WOZ value. In that case buildings can only be amortized to the WOZ value of
the building. There are no changes with respect to the personal income tax, whereby a building in
own use can still be depreciated up to 50% of the WOZ value.
3.3 Fiscal investment institution may no longer directly invest in Dutch
real estate
For fiscal investment institutions (in Dutch: ‘fiscale beleggingsinstellingen’ or FBIs), a corporate
income tax rate of 0% applies. In order to be eligible for this, several requirements need to be met.
These requirements will be tightened as FBIs may no longer directly invest in Dutch real estate as of
1 January 2020.
3.4 Reduction of the corporate income tax rate
The corporate income tax rate is gradually reduced to ultimately 16% in the first bracket (for profits
up to and including €200,000) and 22.25% in the second bracket (for profits €200,000 and up) in
2021.
The tax rate structure of the corporate income tax will be as follows:
Taxable amount Tax rate Taxable amount Tax rate
2018 €0 - €200,000 20.0% €200,000 and up 25.0%
2019 €0 - €200,000 19.0% €200,000 and up 24.3%
2020 €0 - €200,000 17.5% €200,000 and up 23.9%
2021 €0 - €200,000 16.0% €200,000 and up 22.25%
3.5 Limitation of loss setoff in the corporate income tax
In the corporate income tax, losses can currently be offset with
the taxable profit of the prior year (carry back);
the taxable profit of the next nine years (carry forward).
As of 1 January 2019, the carry forward is limited to six years. Losses as per fiscal year 2019 can
then be offset with the taxable profit up to and including 2025. For losses incurred before 2019,
7the current "carry forward" period of nine years applies. A loss incurred in 2018 may thus be offset
with profits at the latest in the fiscal year 2027. In order to ensure the latter, a specific
grandfathering is provided.
3.6 European Anti-Tax Avoidance Directive
The European Anti-Tax Avoidance Directive (ATAD1) includes a number of measures to counteract
base erosion and profit shifting in the corporate income tax:
earnings-stripping measure;
controlled foreign company (CFC) rule;
exit taxation, which provides for a mandatory exit charge in the case of a cross-border
relocation of business activities;
limitation of tax deductions in case of hybrid structures;
general anti-abuse provision.
The measures must be implemented by the Member States, including the Netherlands, into national
legislation and shall enter into force on 1 January 2019.
3.7 Implementation of earnings stripping measure
The implementation of an earnings stripping measure forms part of the European anti-tax
avoidance directive. The earnings stripping measure is a general interest deduction limitation rule
in the corporate income tax which limits the deduction of the surplus of third party and
intercompany interest expenses based on a fixed percentage of the gross operating income
(EBITDA).
3.8 Implementation of Controlled Foreign Company (CFC) rule
The implementation of a CFC rule forms part of the European Anti-Tax Avoidance Directive. This
rule intends to prevent companies from shifting profits to a subsidiary located in a jurisdiction with
a low tax rate. Under the CFC rule, certain categories of a CFCs income are directly included in the
Dutch taxable basis.
3.9 Amendment exit taxation
The deferred payment arrangement in the Dutch exit taxation rules for entities that are liable to
corporate income tax is brought in line with the European anti-tax avoidance directive with respect
to the following two items.
3.10 Abolishment interest deduction limitation rules and limitation rules
for offsetting of losses holding and financing companies
As a result of the introduction of the earnings stripping measure as general interest deduction
limitation rule, the specific interest deduction limitation rules are again reviewed. It is proposed to
abolish the interest deduction limitation rules relating to participation debt, the interest deduction
limitation rule relating to acquisition debt and the limitation of the offsetting of losses for holding
and financing companies (in Dutch: ‘houdsterverliezen’).
8 Instead of the current deferral of payment, only a spread out payment plan of five years is
offered in case of transfer to an EU/EEA country. This payment plan is terminated upon
realization of the profits by the taxpayer.
Based on the current Dutch regulations, the tax authorities may in principle safeguard its
right to levy taxes in all cases in which a deferral of payment is granted. This will be limited.
The levy of tax may now only be safeguarded if there is a demonstrable and actual risk of
non-collection.
For the personal income tax, the current Dutch deferred payment arrangement remains
unchanged.
3.11 Abolishment deduction tier 1 capital banks and insurers
Effectively from 1 January 2019, the deductibility of the remuneration (coupon) of an
supplementary tier 1-capital of banks and insurers is abolished.
94. Dividend tax and witholding tax
4.1 Abolishment dividend withholding tax and introduction source tax in
abuse situations
As of 2020 the dividend withholding tax is abolished. At the same time, a source tax is introduced
on dividend distributions in abuse situations within a group. Starting in 2021, this scheme will be
extended to interest and royalty payments.
It is announced that the dividend withholding tax is abolished as of 2020. Dutch companies can as
of that moment distribute dividends without withholding tax to their foreign shareholders.
105. Turnover tax (VAT)
5.1 Increase of the reduced VAT rate from 6% to 9%
The Tax Plan states that the reduced VAT rate will be increased to 9% per 1 January 2019. The
reduced rate is amongst others applied to food, non-alcoholic beverages and the entrance fee to
museum, theatre performance and music concerts.
5.2 Expansion of the sports exemption for VAT
The Dutch VAT exemption for sport and sport-related activities will be expanded per 1 January
2019. As a result of European developments, the Netherlands was forced to adjust its domestic
exemption. Consequently, more activities will be exempt from VAT.
5.3 Simplification of VAT rules for electronic services
Whereas all entrepreneurs currently need to charge foreign VAT to their private customers in the EU
when they perform electronic services, a threshold will be introduced for this per 1 January 2019.
This simplifies matters for smaller entrepreneurs: if their revenues from such services are less than
€ 10,000 per year, they may charge the VAT of the country in which they are based. The invoicing
rules for such services will also be simplified.
5.4 Simplification of the VAT small business scheme
The small business scheme (‘KOR’, in Dutch ‘kleineondernemersregeling’) will be amended per 1
January 2020. This is set out in a proposal to change the current VAT regulations for small
entrepreneurs. If an entrepreneur based in the Netherlands expects to generate less than € 20,000
a year in revenues (in the Netherlands), he may opt to be "exempted" from VAT from 1 January
2020 onwards. This new KOR is less complex than the current regulation and will also apply for e.g.
foundations, associations and private limited liability companies (‘BVs’).
116. Environmental taxes
6.1 Greening tax measures
The cabinet has proposed various greening tax measures.
EY vision
In general, the greening tax measures are in line with the agreed coalition agreement and thus
present little news. Furthermore, these measures do not demonstrate a great deal of ambition, in
light of the State Secretary's letter on greening taxes earlier this year. The environmental taxes are
only deployed to a very limited extent with regard to achieving the government's ambitious climate
objectives and the plans which have existed for some time to shift taxation from labor to
consumption also seems to lack consistency.
6.2 Amendments to the energy tax rates
Effectively from 1 January 2019, the regular rates in the first brackets of the energy tax for natural
gas will be increased with 3 cents per m3 and for greenhouses with 0.482 cents per m3. At the same
time, the tax rate in the first bracket for electricity is reduced to 0.72 per kWh. This proposal is in
line with the idea of the cabinet stated earlier this year and which was also included in the letter on
greening taxes. The principle of "the polluter pays" will be given a more decisive role and polluting
behavior will as a result be more expensive.
6.3 Amendments to the waste tax
The coalition agreement referred to broadening the basis for the waste tax by abolishing the
exemption for burning sewage sludge and biomass. For the time being this will not be implemented.
The rate will, however, be tripled, which is more than announced. The rate will be increased from €
13.21 to € 31.39 per 1,000 kilograms.
127. Landlord levy
7.1 Tax reduction in the landlord tax
The cabinet introduces a tax reduction in the landlord tax for more sustainable rental homes. This
measure is in line with the government's broader policy and climate objectives. Making homes more
sustainable is an important element in the strategy to achieve the objective of the Paris Climate
Agreement.
138. State Taxes Act
8.1 Protective tax assessment regarding pension upon emigration
A proposal is made entailing that protective tax assessments regarding pension rights and annuity
entitlements may not be imposed to the extent that these relate to:
expenses for annuity entitlements made during the period before 1 January 1992 or during
the period from 1 January 2001 up to and including 15 July 2009;
entitlements and contributions pursuant to a pension scheme that were not considered part
of the wages prior to 16 July 2009.
Protective tax assessments may, however, be imposed on pension rights and annuity entitlements
that are built up after 15 July 2009.
8.2 Amendment tax interest scheme for Personal income tax and
inheritance tax
The underlying principle for the tax interest scheme is that tax interest is charged if the tax
assessment is not imposed due to the taxpayer not fulfilling its obligations. However, in the
Personal income tax and inheritance tax, the situation may occur that the taxpayer is charged with
tax interest despite the fact he fulfils its obligations timely and correctly. This is in contradiction
with the principle of the tax interest scheme and therefore the following measures are undertaken:
If a preliminary income tax assessment is requested or the personal income tax return is
submitted before 1 May in the following year, no tax interest is charged.
If a preliminary inheritance tax assessment is requested or the inheritance tax return is
submitted within eight months after the death, no tax interest is charged.
8.3 Tackling recovery structures
Recently, a large focus has been paid to international tax structures to avoid and possibly evade
taxes (e.g. the Panama Papers). The current possibilities for the Dutch Tax Authorities to collect
taxes from these (international) tax structures are inadequate, resulting in the collection of tax
debts to be seriously imperiled, according to the cabinet. As a result four new collection measures
are being introduced, which are primarily intended to jointly contribute to tackling the recovery
structures.
8.4 The term violator for tax purposes
The term violator for tax purposes is expanded per 1 January 2014 with offender, instigator and the
accomplice. As a result, an administrative penalty may be imposed on parties that deliberately help
others with the non-compliance of their obligations.
This expansion of the term violator was supposed to be eliminated per 1 January 2019. Considering
also the preventive effect, it is proposed to extend the expiration date by five years until 1 January
2024.
148.5 Processing of vehicle registration details
In light of a correct assessment of the motor vehicle taxes, it is necessary that the Dutch Tax
Authorities have the right authorities to collect and use the necessary information. The processing
of vehicle registration details is hereby of great importance. The Supreme Court previously ruled
that the Dutch Tax Authorities was not permitted to use the vehicle registration details for the
auditing the kilometre lodge in the context of the private use of a company car as for a long time an
adequate legal basis was missing to monitor individuals for a longer period.
159. Gambling tax
9.1 Amendment gambling tax for sports betting
The legislative proposal for the Remote Gambling Tax Act (in Dutch: ‘wet Kansspelen op afstand’ or
KOA) is currently subject to approval by the Upper House of Parliament. This would allow the game
providers to access the online market in the Netherlands, and the same tax liability and tax basis
will apply for all remote gambling. The KOA Act is expected to enter into force per 1 June 2020.
1610. Contact
General and procedural tax Labor market and employers
law
Jan-Bertram Rietveld
Arjo van Eijsden E: jan-bertram.rietveld@nl.ey.com
E: arjo.van.eijsden@nl.ey.com T: 088 – 407 78 976
T: 088 – 407 84 11
Innovation and investments Entrepreneurs
Income and Corporate Tax
Ben Kiekebeld Rudolf de Vries
E: ben.kiekebeld@nl.ey.com E: rudolf.de.vries@nl.ey.com
T: 088 – 407 84 57 T: 088 – 407 1145
Entrepreneurs Enterprises
European measures VAT, transfer tax, customs,
environmental taxes
Daniel Smit Walter de Wit
E: daniel.smit@nl.ey.com E: walter.de.wit@nl.ey.com
T: 088 – 407 8499 T: 088 – 407 71 390
Private individuals Wealthy individuals
Rob Boltjes Roxana Bos
E: rob.boltjes@nl.ey.com E: roxana.bos@nl.ey.com
T: 088 – 407 9246 T: 088 – 407 8443
17EY | Assurance | Tax | Transactions | Advisory About EY EY is a global leader in assurance, tax, transaction and advisory services. The insights and quality services we deliver help build trust and confidence in the capital markets and in economies the world over. We develop outstanding leaders who team to deliver on our promises to all of our stakeholders. In so doing, we play a critical role in building a better working world for our people, for our clients and for our communities. EY refers to the global organization, and may refer to one or more, of the member firms of Ernst & Young Global Limited, each of which is a separate Legal entity. Ernst & Young Global Limited, a UK company limited by guarantee, does not provide services to clients. For more information about our organization, pleasevisitey.com. ED NONE This publication contains information in summary form and is therefore intended for general guidance only. It is not intended to be a substitute for detailed research or the exercise of professional judgment. Neither EYGM Limited nor any other member of the global EY organization can accept any responsibility for loss occasioned to any person acting or refraining from action as a result of any material in this publication. On any specific matter, reference should be made to the appropriate advisor. ey.com/nl
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