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Netherlands Corporate - Withholding taxes

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Dividends from Dutch corporations are generally subject to a 15% Dutch dividend WHT. In general, this does not apply to the Dutch cooperative (i.e. ‘co-op’) in a business driven structure, a widely used vehicle for holding and financing activities.

The Netherlands does not levy a WHT on interest and royalty payments.

Domestic corporations are required to withhold taxes as follows:

Recipient Dividends (%) (1)
Resident corporations 0/15
Resident individuals 15
   
Non-resident corporations and individuals:  
Non-treaty situations 15
Treaty:  
Albania 0/5/15 (30)
Argentina 10/15 (2)
Armenia 0/5/15 (3)
Aruba 5/7.5/8.3/15 (5, 21, 40)
Australia 15 (5)
Austria 0 (6) or 5/15 (3, 7)
Azerbaijan 5/10 (38)
Bahrain 0/10 (8)
Bangladesh 10/15 (8)
Barbados 0/15 (42)
Belarus 0/5/15 (2, 9)
Belgium 0 (6) or 5/15 (5, 8)
Bosnia Herzegovina 5/15 (2, 4)
Brazil 15 (5)
Bulgaria 0 (6)/5/15 (2)
Canada 5/15 (10)
Caribbean Netherlands (Bonaire, Saint Eustatius, and Saba) 0/15 (41)
China, People's Republic of 10 (5, 11)
Croatia 0/15 (6, 8)
Curaçao 0/15 (5, 46)
Czech Republic 0 (6) or 0/10 (2, 5)
Denmark 0 (6) or 0/15 (8)
Egypt 0/15 (2)
Estonia 0 (6) or 5/15 (2)
Ethiopia 5/15 (45)
Finland 0 (6) or 0/15 (37)
France 0 (6) or 5/15 (2, 5)
Georgia 0/5/15 (31)
Germany 0 (6) or 5/10/15 (12)
Ghana 5/10 (8)
Greece 0 (6) or 5/15 (2)
Hong Kong 0/10 (42)
Hungary 0 (6) or 5/15 (2)
Iceland 0/15 (8)
India 10/15 (32)
Indonesia 10 (2, 5)
Ireland, Republic of 0 (6) or 0/15 (13)
Israel 5/15 (2)
Italy 0 (6) or 5/10/15 (14)
Japan 0/5/10 (15)
Jordan 5/15 (8)
Kazakhstan 0/5/15 (17)
Korea, Republic of 10/15 (2)
Kuwait 0/10 (8)
Kyrgyzstan 15 (5, 24)
Latvia 0 (6) or 5/15 (2)
Lithuania 0 (6) or 5/15 (2)
Luxembourg 0 (6, 18) or 2.5/15 (2, 18)
Macedonia 0/15 (8)
Malawi 0/5/15 (19)
Malaysia 0/15 (7)
Malta 0 (6) or 5/15 (2)
Mexico 5/15 (16)
Moldavia 0/5/15 (20)
Mongolia 0/15 (44)
Montenegro 5/15 (2, 4)
Morocco 10/15 (2)
New Zealand 15 (5)
Nigeria 12.5/15 (8)
Norway 0/15 (2)
Oman 0/10 (8)
Pakistan 10/15 (2)
Panama 0/15 (42)
Philippines 10/15 (8)
Poland 0 (6) or 5/15 (5, 8)
Portugal 0 (6)/10
Qatar 0/10 (39)
Romania 0 (6) or 0/5/15 (22)
Russian Federation 5/15 (23)
Saint Martin 0/15 (5, 46)
Saudi Arabia 5/10 (8)
Serbia 5/15 (2, 4)
Singapore 0/15 (5, 7)
Slovak Republic 0 (6) or 0/10 (2, 5)
Slovenia 0 (6) or 5/15 (2)
South Africa 5/10 (16)
Spain 0 (6) or 5/15 (5, 25)
Sri Lanka 10/15 (2)
Surinam 7.5/15 (2)
Sweden 0 (6) or 0/15 (2)
Switzerland 0/15 (36, 43)
Taiwan 10
Tajikistan 15 (24)
Thailand 5/15 (34)
Tunisia 0/15 (8)
Turkey 5/15 (2)
Turkmenistan 15 (5, 24)
Uganda 0/5/15 (35)
Ukraine 0/5/15 (26)
United Arab Emirates 5/10 (8)
United Kingdom 0 (6) or 0/10/15 (33)
United States 0/5/15 (27)
Uzbekistan 0/5/15 (28)
Venezuela 0/10 (2)
Vietnam 5/7/15 (29)
Zambia 5/15 (2)
Zimbabwe 10/15 (2)

Notes

  1. A 0% WHT rate applies to payments to a resident corporation when its shareholding qualifies for the participation exemption and the shares form part of a company whose activities are carried on in the Netherlands. However, dividend WHT may be levied on certain profit participating loans.
  2. The lower rate applies if the foreign company directly owns at least 25% of the capital of the Dutch company.
  3. The 5% rate is applicable if the foreign company directly owns 10% of capital of the Dutch company. The 0% rate is applicable if the dividend originates from ordinary taxed profits and the dividend is tax exempt in the hands of the recipient.
  4. Based upon the treaty concluded with former Yugoslavia.
  5. Negotiations on (revisions of) tax treaties are currently pending with Angola, Aruba Australia, Belgium, Brazil, Chile, Colombia, Costa Rica, France, Indonesia, Kenya, New Zealand, Poland, Saint Martin, Singapore, Slovak Republic, and Spain. The revised treaty with the Czech Republic is signed but not yet effective.
  6. Indicates that this country is a member state of the European Union. The EU Parent/Subsidiary Directive applies from 1 January 1992. According to the Directive, dividends paid by a Dutch company (BV or NV) to a qualifying parent company resident in another EU member state must be exempt from Dutch WHT, provided certain conditions are met. Among other things, the EU parent company must hold at least 10% of the Dutch dividend-paying company’s capital (or, in certain cases, voting rights) for a continuous period of at least one year. Please note that the Dutch tax legislation is more lenient with respect to the minimum holding; it only requires a holding of 5% at the moment of distribution. A provisional exemption from dividend WHT will apply from the start of the one-year holding period. The exemption will be cancelled retroactively if, following the dividend distribution, the one-year holding requirement is not actually met. The Dutch dividend-distributing company must provide to the Dutch tax authorities a satisfactory guarantee for the payment of dividend WHT that, but for the provisional exemption, would be due. The exemption is also applicable if the parent company is a resident of a EU member state and owns at least 10% of the (voting) shares in the Dutch company but only on the basis of reciprocity (Finland, Germany, Greece, Luxembourg, Spain, and United Kingdom). Should the WHT exemption not be available under the EU Parent/Subsidiary Directive, the treaty rate(s) set out in the right-hand side of the same column (following ‘or’) will apply.
  7. The lower rate applies if the foreign company directly or indirectly owns at least 25% of the capital of the Dutch company.
  8. The lower rate applies if the foreign company directly owns at least 10% of the capital of the Dutch company.
  9. The 0% rate applies if the foreign company directly owns at least 50% of the capital of the Dutch company, or invested more than EUR 250,000 in the Dutch company or directly owns 25% of the capital of the Dutch company and has a statement indicating that the investment in Dutch capital is, directly or indirectly, guaranteed by the government of Belarus.
  10. The 5% rate applies if the foreign company directly or indirectly owns at least 25% of the capital or at least 10% of the voting rights in the Dutch company.
  11. The treaty is not applicable for Hong Kong and Taiwan.
  12. The 5% of rate applies if the beneficial owner is a company (other than a partnership) that directly holds at least 10% of the capital of the payer company. The 10% rate applies if the beneficial owner is a pension fund that is resident in the Netherlands. The 15% rate applies in other cases.
  13. The lower rate applies if the foreign company owns at least 25% of the voting rights in the Dutch company.
  14. The 5% rate is applicable if the Italian company owns at least 50% of the voting shares in the Dutch company for a continuous period of at least 12 months prior to the date chosen for distribution of a dividend. The 10% rate is applicable if the Italian company owns at least 10% of the voting shares in the Dutch company for the continuous period mentioned above. In other cases, the dividend WHT rate is 15%.
  15. The 5% rate applies if the foreign company owns at least 10% of the voting shares of the Dutch company for a continuous period of at least six months immediately before the end of the book year to which the dividend distribution relates. No WHT is levied if the foreign company directly or indirectly owns at least 50% of the voting power in the Dutch company distributing the dividends for a period of six months. Also, no WHT is levied if the foreign company is a pension fund.
  16. The lower rate applies if the foreign company directly or indirectly owns at least 10% of the capital of the Dutch company.
  17. The 0% rate is applicable if the foreign company directly or indirectly owns at least 50% of the capital of the Dutch company or if it has invested more than 1 million United States dollars (USD) in the Dutch company, insofar as the government of Kazakhstan has guaranteed the investment; the 5% rate applies if the recipient company owns at least 10% of the capital of the paying company.
  18. These rates do not apply to dividend payments to Luxembourg ‘1929’ holding companies.
  19. A 0% rate is only applicable to certain pension funds. The 5% rate is applicable only to shareholdings of at least 10%.
  20. The 0% rate is applicable if the foreign company directly or indirectly owns at least 50% of the capital of the Dutch company and invested more than USD 300,000 in the Dutch company. The 5% rate is applicable if the foreign company directly owns 25% or more of the capital of the Dutch company. The 15% rate is applicable on portfolio investments.
  21. The rate is 15% unless the dividend is paid to a company holding at least 25% of the paid-up capital in the Dutch company. In this latter case, the WHT rate will be reduced to: (i) 5% if the dividends received are subject to a profits tax in the other state of at least 5.5% on the dividend or (ii) 7.5% if the profits tax is less than 5.5%. The combined CIT of the other state and Dutch dividend WHT for participations of at least 25% must not exceed 8.3%. Depending on the tax percentage levied in the other state, the Dutch dividend WHT will be restituted accordingly.
  22. The 5% rate is applicable if the recipient of the dividend is the beneficial owner and directly owns 10% of the capital of the Dutch company. The 0% rate is applicable if the recipient of the dividend is the beneficial owner and directly owns at least 25% of the capital of the Dutch company.
  23. The 5% rate is applicable if the recipient of the dividend is the beneficial owner and directly owns at least 25% in the capital of the Dutch company with a minimum investment of at least EUR 75,000.
  24. The Netherlands applies the treaty with the former Soviet Union unilaterally to Kyrgyzstan, Tajikistan, and Turkmenistan.
  25. The lower treaty rate applies if the Spanish company owns 50% or more of the capital of the Dutch company or if the Spanish company owns 25% or more of the capital of the Dutch company and another Spanish company also owns 25% or more of that capital.
  26. The 0% rate is applicable if the foreign company directly or indirectly owns at least 50% of the capital of the Dutch company or invested more than USD 300,000 in the Dutch company. The 5% rate is applicable if the foreign company directly owns 20% or more of the capital of the Dutch company.
  27. The lower rate applies if the foreign company directly owns at least 10% of the voting rights in the Dutch company. On 8 March 2004, the Netherlands and the United States signed a protocol amending the applicable tax treaty. Based on this protocol, the WHT on dividends will be reduced to 0% if the receiving company owns 80% or more of the voting power of the distributing company, provided that certain other conditions are also met. This reduction of the dividend WHT has taken effect as of 1 January 2005.
  28. The 5% rate is applicable if the foreign company directly owns 25% or more of the capital of the Dutch company. The 0% rate is applicable if the dividend for that company qualifies for the participation exemption in the Netherlands. The 15% rate is applicable to portfolio dividends.
  29. The 5% rate is applicable if the foreign company directly or indirectly owns at least 50% of the capital of the Dutch company or invested more than USD 10 million in the Dutch company. The 7% rate applies to the foreign company owning, directly or indirectly, at least 25% of the capital of the Dutch company.
  30. No dividend WHT is due if the share in the participation is at least 50% and at least USD 250,000 capital is paid in, in the participation. A dividend WHT of 5% is due if the share in the participation is at least 25%.
  31. A dividend WHT of 5% is due if the share in the participation is at least 10%. No dividend WHT is due if the share in the participation is at least 50% and at least USD 2 million capital is paid in, in the participation.
  32. Based upon most-favoured nation principle.
  33. The 0% rate applies if a company controls at least 10% of the voting power of the Dutch company paying the dividends. The 15% rate applies to dividends arising from income from immovable property, distributed by certain tax exempt real estate investment vehicles (e.g. REITs or FBIs).
  34. In case a Thai company holds at least a 25% share in a Thai company, the Dutch dividend WHT rate is 5%.
  35. If a share of at least 50% is held by a company, no dividend WHT is due. If the share the company holds is less than 50%, 5% dividend WHT is due.
  36. As of 29 December 2004, Switzerland and the European Union concluded a treaty in light of the EU Savings Directive. The treaty, amongst others, contains a clause that no dividend tax is withheld if certain requirements are met. The main requirements are that a shareholding of at least 25% is held directly for a period of at least two years and both corporations are not subjected to a special tax regime. Please note that even though the treatment of dividend appears to be equal to the treatment on the basis of the EU Parent-Subsidiary Directive, the Directive is, in fact, not applicable to Switzerland.
  37. The 0% rate applies if the foreign company directly owns at least 5% of the capital of the Dutch company.
  38. The 5% rate applies if the foreign company directly owns at least 25% of the capital of the Dutch company with a minimum investment of at least EUR 200,000 in the Dutch company.
  39. The 0% rate applies if the foreign company directly owns at least 7.5% of the capital of the Dutch company.
  40. The WHT rates are based on the Dutch ‘Belastingregeling voor het Koninkrijk’.
  41. The WHT rates for the Caribbean Netherlands are based on the Dutch ‘Belastingregeling voor het land Nederland’.
  42. No WHT is levied if the foreign company (beneficial owner) receiving the dividends directly holds at least 10% (15% threshold for the Panama Treaty) of the shares of the Dutch company, provided that the shares of the foreign company are regularly traded on a recognised stock exchange or at least 50% of the shares of the foreign company is owned by residents of either contracting state or by companies the shares of which are regularly traded on a recognised stock exchange. Also, no WHT is levied if the foreign company is a bank or insurance company, a state or political subdivision, a headquarter owning at least 10% of the shares of the Dutch company, or a pension fund.
  43. The 0% rate applies if the foreign company directly owns at least 10% of the capital of the Dutch company, is a pension fund, or, as far as Switzerland is concerned, the beneficial owner is a social security scheme.
  44. Because the treaty with Mongolia is not applicable anymore, the national WHT rate applies.
  45. The 5% rate applies if the foreign company is the beneficial owner of the dividends and directly owns at least 10% of the capital of the Dutch company or is a pension fund.
  46. The 0% rate applies if the shareholder is a pension fund or a governmental entity. The 0% rate also applies if the foreign company is the beneficial owner of the dividends and directly owns at least 10% of the capital of the Dutch company and meets one or more of the following criteria: it is listed on a recognised stock exchange, more than 50 of the shares is held by an entity listed at a recognised stock exchange, is the head office of a multinational or engages in group financing, has at least three qualifying employees, is commercially active and the dividends are connected to the business activities, is commercially active and the main purpose of the entity or shareholding is not the benefits of the tax arrangement, the shares are held for more than 50% by natural persons resident in the Netherlands or the other state.

Last Reviewed - 01 December 2017

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