Friday, 7 July 2017

Netherlands seeks comments on dividend withholding tax proposal affecting cooperatives and BVs/NVs

Draft legislative amendments to the Dutch Dividend Withholding Tax Act on the withholding tax position of Dutch cooperatives (the Consultation Document) are open for consultation from May 16, 2017, through June 13, 2017. The Consultation Document is not yet a formal legislative proposal but rather a draft proposal. The Consultation Document seeks to align the dividend withholding tax treatment of holding cooperatives with that 0f Dutch tax-resident entities with capital divided into shares (BVs/NVs).

The Consultation Document also proposes introducing a more extensive unilateral dividend withholding tax exemption in conjunction with anti-abuse rules along the lines of Action 6 of the Organisation for Economic Co-operation and Development (OECD) Base Erosion and Profit Shifting (BEPS) project.

The Dutch Ministry of Finance believes the draft proposal, if enacted, will address European Commission observations on differential treatment of cooperatives, maintain a strong fiscal investment climate, and counter international tax avoidance through the use of Dutch cooperatives in specific situations.

Source & more info: PwC