What changes?
A withholding tax on dividend flows to tax havens will be introduced. This tax will apply to all financial flows to countries that have a profit tax of less than 9%. It also applies to all countries that have been listed (pdf) as tax havens by the European Union. This is also the case if the Netherlands have a tax treaty with any of these countries.
This new withholding tax is introduced in addition to the withholding tax on outgoing interest and royalties (in Dutch) that came into effect in 2021.
For whom?
- companies with cash flows from or through the Netherlands to countries that tax them little or nothing
- tax consultants
When?
This change is expected to come into force on 1 January 2024.
Please note: The effective date of this measure is not yet final. Entry into force is subject to its passing through the upper and lower houses of parliament or proclamation of the Order in Council (Algemene Maatregel van Bestuur, AMvB) or ministerial decree and publication in the Staatsblad or Staatscourant(in Dutch).
