Netherlands: Country and Foreign Investment
Antilles and Aruba
Curacao (the Netherlands Antilles until October 2010) and Aruba have a special role to play in making Holland an attractive jurisdiction in which to base international holding and trading operations. Dividends paid by a Dutch corporation to a Netherlands Antilles or Aruban company are subject to reduced withholding tax rates. This is a very unusual arrangement since Netherlands Antilles and Aruba are offshore jurisdictions which don't normally have double tax treaties with high-tax countries.
In 2010, the standard Dutch withholding tax rate on dividends of 15% can be reduced to a rate of 5% on dividends remitted to a Netherlands Antilles company provided that the Netherlands Antilles company satisfies minimum share holding criteria.
In 2012, there have been some issues with regard to taxation of dividends since the break-up of the Netherlands Antilles). However, at the time of writing a 0% rate applies to active companies with qualifying participation. The maximum rate of 5% withholding tax applies to dividends paid by a Dutch corporation to a Curacao company.