Netherlands (NL)

Jurisdiction Overview

IDQuestionAnswer
552 *Legal Person, Resident, Independent Party: Dividends Exemption.
 Data Date: 2019

Notes

 
Participation exemption is available for shareholdings of 5% or more of the issued and paid-up capital of the foreign company (IBFD 2019b: 7.2.6.2.2.). There are however several sitautions where shares that are held for investment (portfolio shares) are considered "qualifying" as relating to a substantial corporate shareholder. (IBFD 2019b: 6.1.3.). Thus, because the threshold for the participation exemption is 5%, and regulations allow for a very broad applicability of the exemption, we consider that the regime also applies to dividends received from an "independent party". Furthermore, investment institutions are available in the Netherlands, and these are either taxed (at 0%) or tax-exempt (IBFD 2019b: 12.2.2.). We consider that foreign dividends received by such companies are generally tax-exempt.

Sources

IBFD 2019b
 
https://ttp://taxsummaries.pwc.com/ID/Netherlands-Corporate-Income-determination