Netherlands - New Withholding Tax on Interest, Royalties and Dividends

A conditional withholding tax on interest and royalties was introduced per 1 January 2021. The intention is to extend this conditional withholding tax on interest and royalties to include dividend payments in 2024. The Netherlands has never had a (conditional) withholding tax on interest and royalties until 2021. The conditional withholding tax on interest and royalties will apply in the case of direct payments to entities established in low-tax jurisdictions, in the case of abuse or to certain hybrid structures. The introduction of a conditional withholding tax on interest and royalties will have a major impact on international group financing and licensing structures. To illustrate this, the authors have included examples where international structures are impacted.