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Netherlands: Double Tax Treaties

Table of Treaty Rates

Provided by TreatyPro
Netherlands


Jurisdiction Status Dividends Interest Royalties Notes
           
Defaults 15% 0% 0%
           
Albania Effective January 1, 2006 5% where the payee is a company holding at least 25% of the paying company's capital 10% where the payee is a company holding at least 50% of the paying company's capital with a minimum investment of USD250,000 or equivalent 15% 0% 0%
Argentina Effective January 1, 1999 10% where the payee is a company (excluding a partnership) holding directly at least 25% of the paying company's capital 15% 0% 0%
Armenia Effective January 1, 2003 5% where the payee is a company (excluding a partnership) holding directly at least 10% of the paying company's capital 15% 0% 0%
Aruba Effective January 1, 2012 5% when the Aruban corporate tax rate is at least 5.5% 7.5% where the payee is a company holding at least 25% of the paying company's capital 15% 0% 0%
Australia Effective January 1, 1975 15% 0% 0%
Austria Effective January 1, 1969 Protocol effective July 1, 1990 5% where the payee is a company holding at least 25% of the paying company's capital 15% 0% 0%
Azerbaijan Effective January 1, 2010 5% where the payee is a company holding directly at least 25% of the paying company's capital with a minimum investment of EUR200,000 or equivalent 10% 0% 0%
Bahrain Effective January 1, 2010 0% where the payee is a company holding directly at least 10% of the paying company's capital 10% 0% 0%
Bangladesh Effective January 1, 1995 10% where the payee is a company (excluding a partnership) holding directly at least 10% of the paying company's capital 15% 0% 0%
Barbados Effective January 1, 2008 Protocol effective December 13, 2011 0% where the payee is a company holding directly at least 10% of the paying company's capital, the government, a pension fund, a bank, an insurance company, or a headquarters company for a multinational corporate group 15% 0% 0%
Belarus Effective January 1, 1998 0% where the payee is a company (excluding a partnership) holding directly at least 50% of the paying company's capital with a minimum investment of EUR250,000 or equivalent, or a company (excluding a partnership) holding directly at least 25% of the paying company's capital, and this investment is guaranteed or insured by the government 5% where the payee is a company (excluding a partnership) holding directly at least 25% of the paying company's capital 15% 0% 0%
Belgium Effective January 1, 2003 5% where the payee is a company holding directly at least 10% of the paying company's capital 15% 0% 0%
Bosnia and Herzegovina Effective January 1, 1984 5% where the payee is a company (excluding a partnership) holding directly at least 25% of the paying company's capital 15% 0% 0% The Yugoslavia treaty continues to apply.
Brazil Effective January 1, 1992 15% 0% 0%
Bulgaria Effective January 1, 1995 5% where the payee is a company (excluding a partnership) holding directly at least 25% of the paying company's capital 15% 0% 0%
Canada Effective January 1, 1987 Protocol effective January 15, 1999 5% where the payee is a company (excluding a partnership) holding at least 25% of the paying company's capital or at least 10% of its voting stock 15% 0% 0%
China Effective January 1, 2015 0% when paid to the government 5% where the payee is a company (excluding a partnership) holding directly at least 25% of the paying company's capital 10% 0% 0%
Croatia Effective January 1, 2002 0% where the payee is a company holding directly at least 10% of the paying company's capital 15% 0% 0%
Czech Republic Effective January 1, 1972 0% where the payee is a company holding directly at least 25% of the paying company's capital 10% 0% 0% The Czechoslovakia treaty continues to apply.
Denmark Effective January 1, 1999 0% where the payee is a company holding directly at least 10% of the paying company's capital 15% 0% 0%
Egypt Effective January 1, 2001 0% where the payee is a company holding directly at least 25% of the paying company's capital 15% 0% 0%
Estonia Effective January 1, 1995 5% where the payee is a company (excluding a partnership) holding directly at least 25% of the paying company's capital 15% 0% 0%
Ethiopia Signed August 10, 2012 5% where the payee is a company (excluding a partnership) holding directly at least 10% of the paying company's capital, or a pension fund 15% 0% 0% Not yet in force. Default rates apply.
Finland Effective January 1, 1998 0% where the payee is a company holding directly at least 5% of the paying company's capital, or a pension fund 15% 0% 0%
France Effective March 19, 1974 5% where the payee is a company holding directly at least 25% of the paying company's capital 15% 0% 0%
Georgia Effective January 1, 2004 5% where the payee is a company holding at least 10% of the paying company's capital 10% where the payee is a company holding at least 50% of the paying company's capital with a minimum investment of USD2m or equivalent 15% 0% 0%
Germany Effective January 1, 1956 New treaty signed April 12, 2012 10% where the payee is a company holding at least 25% of the paying company's voting stock 15% When new treaty is effective: 5% where the payee is a company (excluding a partnership) holding directly at least 10% of the paying company's capital 10% 0% 0% New treaty not yet in force.
Ghana Effective January 1, 2009 5% where the payee is a company (excluding a partnership) holding directly at least 10% of the paying company's capital 10% 0% 0%
Greece Effective January 1, 1981 5% where the payee is a company (excluding a partnership) holding directly at least 25% of the paying company's capital 15% 0% 0%
Hong Kong Effective January 1, 2011 0% where the payee is a company (excluding a partnership) holding directly at least 10% of the paying company's capital, the government, a pension fund, a bank, an insurance company, or a headquarters company for a multinational corporate group 10% 0% 0%
Hungary Effective January 1, 1988 5% where the payee is a company (excluding a partnership) holding directly at least 25% of the paying company's capital 15% 0% 0%
Iceland Effective January 1, 1999 0% where the payee is a company (excluding a partnership) holding directly at least 10% of the paying company's capital 15% 0% 0%
India Effective January 1, 1987 5% where the payee is a company holding directly at least 10% of the paying company's capital 15% 0% 0% (3)
Indonesia Effective January 1, 2004 10% 0% 0%
Iran Effective January 1, 1970 15% where the payee is a company holding directly at least 25% of the paying company's capital and voting stock 20% 0% 0%
Ireland Effective January 1, 1965 0% where the payee is a company holding directly at least 25% of the paying company's voting stock 15% 0% 0%
Israel Effective January 1, 1970 Protocol effective January 1, 1996 5% where the payee is a company holding directly at least 25% of the paying company's capital 10% where the payee is a company holding directly at least 25% of the paying company's capital, and the dividends are exempt or taxed at a lower rate in Israel 15% 0% 0%
Italy Effective November 1, 1993 5% where the payee is a company holding more than 50% of the paying company's voting stock for 12 months before the dividend is declared 10% where the payee is a company holding at least 10% of the paying company's voting stock for 12 months before the dividend is declared 15% 0% 0%
Japan Effective January 1, 2012 0% where the payee is a company holding at least 50% of the paying company's voting stock for six months before the dividend is declared, or a pension fund 5% where the payee is a company holding at least 10% of the paying company's voting stock for six months before the dividend is declared 10% 0% 0%
Jordan Effective January 1, 2008 5% where the payee is a company holding directly at least 10% of the paying company's capital 15% 0% 0%
Kazakhstan Effective January 1, 1996 5% where the payee is a company holding at least 10% of the paying company's capital 15% 0% 0%
Korea, South Effective January 1, 1981 10% where the payee is a company holding directly at least 25% of the paying company's capital 15% 0% 0%
Kuwait Effective May 23, 2002 0% where the payee is a company holding directly at least 10% of the paying company's capital 10% 0% 0%
Latvia Effective January 1, 1996 5% where the payee is a company (excluding a partnership) holding directly at least 25% of the paying company's capital 15% 0% 0%
Lithuania Effective January 1, 2001 5% where the payee is a company (excluding a partnership) holding directly at least 25% of the paying company's capital 15% 0% 0%
Luxembourg Effective January 1, 1967 2.5% where the payee is a company holding directly at least 25% of the paying company's capital 15% 0% 0%
Macedonia Effective January 1, 2000 0% where the payee is a company holding directly at least 10% of the paying company's capital 15% 0% 0%
Malaysia Effective January 1, 1985 0% where the payee is a company holding at least 25% of the paying company's capital 15% 0% 0%
Malta Effective January 1, 1976 5% where the payee is a company holding directly at least 25% of the paying company's capital 15% 0% 0%
Mexico Effective January 1, 1995 5% where the payee is a company holding at least 10% of the paying company's capital 15% 0% 0%
Moldova Effective January 1, 2002 0% where the payee is a company (excluding a partnership) holding directly at least 50% of the paying company's capital with a minimum investment of USD300,000 or equivalent, or a company (excluding a partnership) whose investment is guaranteed or insured by the government or the central bank 5% where the payee is a company (excluding a partnership) holding directly at least 25% of the paying company's capital 15% 0% 0%
Mongolia Effective January 1, 2004 0% where the payee is a company holding directly at least 10% of the paying company's capital 15% 0% 0%
Morocco Effective July 1, 1987 10% where the payee is a company holding directly at least 25% of the paying company's capital 15% (4) 0% 0%
Netherlands Antilles Effective January 1, 2012 8.3% where the payee is a company holding at least 25% of the paying company's capital 15% 0% 0%
New Zealand Effective January 1, 1979 15% 0% 0%
Nigeria Effective January 1, 1993 12.5% where the payee is a company (excluding a partnership) holding directly at least 10% of the paying company's capital 15% 0% 0%
Norway Effective January 1, 1991 Protocol effective January 1, 2014 0% where the payee is a company (excluding a partnership) holding directly at least 10% of the paying company's capital, the government, the central bank or a pension fund 10% 0% 0%
Oman Effective January 1, 2012 0% where the payee is a company (excluding a partnership) holding directly at least 10% of the paying company's capital, the government, the central bank or a pension fund 10% 0% 0%
Pakistan Effective January 1, 1982 10% where the payee is a company (excluding a partnership) holding directly at least 25% of the paying company's capital 15% (4) 0% 0%
Panama Effective January 1, 2012 0% where the payee is a company holding directly at least 15% of the paying company's capital, the government, a pension fund or a headquarters company for a multinational corporate group 15% 0% 0%
Philippines Effective January 1, 1992 10% where the payee is a company holding directly at least 10% of the paying company's capital 15% 0% 0%
Poland Effective January 1, 2004 5% where the payee is a company (excluding a partnership) holding directly at least 10% of the paying company's capital 15% 0% 0%
Portugal Effective January 1, 2001 10% 0% 0%
Qatar Effective January 1, 2010 0% where the payee is a company holding directly at least 7.5% of the paying company's capital 10% 0% 0%
Romania Effective January 1, 2000 0% where the payee is a company (excluding a partnership) holding directly at least 25% of the paying company's capital 5% where the payee is a company (excluding a partnership) holding directly at least 10% of the paying company's capital 15% 0% 0%
Russia Effective January 1, 1999 5% where the payee is a company (excluding a partnership) holding directly at least 25% of the paying company's capital with a minimum investment of EUR75,000 or equivalent 15% 0% 0%
Saudi Arabia Effective January 1, 2011 5% where the payee is a company (excluding a partnership) holding directly at least 10% of the paying company's capital 10% 0% 0%
Montenegro Effective January 1, 1984 5% where the payee is a company (excluding a partnership) holding directly at least 25% of the paying company's capital 15% 0% 0% The Yugoslavia treaty continues to apply.
Singapore Effective January 1, 1968 0% where the payee is a company holding at least 25% of the paying company's capital 15% 0% 0%
Slovakia Effective January 1, 1972 0% where the payee is a company holding directly at least 25% of the paying company's capital 10% 0% 0% The Czechoslovakia treaty continues to apply.
Slovenia Effective January 1, 2006 5% where the payee is a company (excluding a partnership) holding at least 10% of the paying company's capital 15% 0% 0%
South Africa Effective January 1, 2009 5% where the payee is a company holding at least 10% of the paying company's capital 10% 0% 0%
Spain Effective January 1, 1973 5% where the payee is a company holding at least 50% of the paying company's capital, or where two companies are each holding at least 25% of the paying company's capital 15% 0% 0%
Sri Lanka Effective January 1, 1979 10% where the payee is a company (excluding a partnership) holding directly at least 25% of the paying company's capital 15% 0% 0%
Suriname Effective November 25, 1975 7.5% where the payee is a company holding directly at least 25% of the paying company's capital 15% (4) 0% 0%
Sweden Effective January 1, 1993 0% where the payee is a company (excluding a partnership) holding directly at least 25% of the paying company's capital 15% 0% 0%
Switzerland Effective January 1, 2012 0% where the payee is a company holding directly at least 10% of the paying company's capital, a pension fund or a Swiss social security scheme 15% 0% 0%
Taiwan Effective July 1, 2001 10% 0% 0%
Thailand Effective January 1, 1976 5% where the payee is a company holding directly at least 25% of the paying company's capital 15% (4) 0% 0%
Tunisia Effective January 1, 1996 0% where the payee is a company holding directly at least 10% of the paying company's capital 15% (4) 0% 0%
Turkey Effective January 1, 1989 15% (4) 0% 0%
Uganda Effective November 1, 2006 0% where the payee is a company holding directly at least 50% of the paying company's capital 5% where the payee is a company holding directly less than 50% of the paying company's capital 15% 0% 0%
Ukraine Effective January 1, 1997 0% where the payee is a company (excluding a partnership) holding directly at least 50% of the paying company's capital with a minimum investment of USD300,000 or equivalent, or a company (excluding a partnership) whose investment is guaranteed or insured by the government or the central bank 5% where the payee is a company (excluding a partnership) holding directly at least 20% of the paying company's capital 15% 0% 0%
United Arab Emirates Effective January 1, 2011 0% when paid to the government, the central bank or a pension fund 5% where the payee is a company holding directly at least 10% of the paying company's capital 10% 0% 0%
United Kingdom Effective January 1, 2011 0% where the payee is a company holding at least 10% of the paying company's voting stock, a pension fund or an organisation for religious, charitable, scientific, cultural, or educational purposes 10% 15% where the payee is an investment vehicle and the dividends are paid out of immovable property income 0% 0%
United States Effective January 1, 1994 Protocol effective February 1, 2005 0% where the payee is a company holding directly at least 80% of the paying company's voting stock for 12 months before the dividend is declared 5% where the payee is a company holding directly at least 10% of the paying company's voting stock 15% 0% 0% Separate dividend withholding tax rules apply to REITs.
Uzbekistan Effective January 1, 2003 5% where the payee is a company holding directly at least 25% of the paying company's capital 15% 0% 0%
Venezuela Effective January 1, 1998 0% where the payee is a company holding directly at least 25% of the paying company's capital 10% 0% 0%
Vietnam Effective January 1, 1996 5% where the payee is a company holding at least 50% of the paying company's capital, or has invested a minimum of USD10m or equivalent 10% where the payee is a company holding at least 25% of the paying company's capital 15% 0% 0%
Zambia Effective January 1, 1983 5% where the payee is a company holding directly at least 25% of the paying company's capital 15% 0% 0%
Zimbabwe Effective April 21, 1991 10% where the payee is a company (excluding a partnership) holding directly at least 25% of the paying company's capital 15% (4) 0% 0%
Serbia Effective January 1, 1984 5% where the payee is a company (excluding a partnership) holding directly at least 25% of the paying company's capital 15% 0% 0% The Yugoslavia treaty continues to apply.
Kosovo Effective January 1, 1984 5% where the payee is a company (excluding a partnership) holding directly at least 25% of the paying company's capital 15% 0% 0% The Yugoslavia treaty continues to apply.

Footnotes

  1. In the case of European Union countries, the EC Parent-Subsidiary Directive can reduce dividend withholding tax to 0%, subject to certain conditions.
  2. Netherlands' default interest and royalties withholding tax rate is 0%. A treaty may stipulate a higher rate.
  3. Netherlands' treaty with India provides a 15% rate for dividends. The treaty does, however, have a most favoured nation clause which provides for a reduction of the withholding tax on dividends if, after the signing of the treaty, India signs a new treaty with another OECD Member State providing for a lower withholding tax rate on dividends. The 2003 India-Slovenia treaty, which entered into effect in 2006, provides for a 5% withholding tax on dividends where the payee is a company holding directly at least 10% of the paying company's capital. Slovenia joined the OECD on 21 July 2010.
  4. The treaty specifies a different rate but the default rate is lower and would therefore apply.
  5. PLEASE NOTE: This table was last updated February 2015

 

 

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