AMSTERDAM: From 2018 the scope of the Dutch dividend withholding tax exemption is extended to shareholders resident in jurisdictions that have a tax treaty with the Netherlands.
On 19 September 2017 the Dutch caretaker government published its Tax Plan 2018. One of the main topics is a positive overhaul of the dividend withholding tax regime. From 1 January 2018, the scope of the Dutch dividend withholding tax exemption will be extended to shareholders resident in jurisdictions that have a tax treaty with the Netherlands. An exemption from Dutch dividend withholding tax is currently only available to corporate residents of the European Union or European Economic Area. ‘Holding’ Cooperatives (whose activities consist for more than 70% of holding or group financing activities) will become subject to Dutch dividend withholding tax, while ‘operational’ Cooperatives remain outside of the scope of Dutch dividend withholding tax. One of the examples in the legislative proposal of an operational Cooperative is a Cooperative with holding activities with the relevant substance to actively manage its subsidiaries, such a private equity companies.
