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New withholding tax on interest, royalties and dividends electrónico Evert-Jan Spoelder and Johan Loo

By: Spoelder, Evert Jan.
Contributor(s): Loo, Johan.
Material type: ArticleArticlePublisher: 2020Subject(s): INTERES | PROPIEDAD INDUSTRIAL | DIVIDENDOS | IMPUESTOS | PAISES BAJOS In: Finance and Capital Markets v. 22, n. 4, 2020Summary: 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.
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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.

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