International Structures

Dutch Tax Treaties: What They Mean for Your BV

Updated: 6 October 2026 Holdwise editorial team Tax treaties International Withholding tax

A tax treaty is an agreement between two countries about who may tax what. If two countries both tax the same income, you pay tax on it twice. You pay once where the income is earned and once where you live. The Netherlands has around 100 of these agreements. This is one of the main reasons international founders set up a company here. At Holdwise, we keep this answer up to date. You find the steps further down this page.

Why tax treaties exist

Income from another country can be taxed in two countries. For example, your Dutch company pays a dividend to a shareholder in Spain. The Netherlands taxes the dividend because the money is earned here. Spain taxes it because the shareholder lives there. The same dividend is then taxed twice.

In a tax treaty, the two countries agree who taxes what, and how much. The country where the income comes from may charge tax up to a maximum. The country where you live gives you a credit for the tax you already paid.

What a treaty contains

Every treaty has the same main parts, in roughly the same order.

Who is covered. A treaty applies to people and companies that are resident in one of the two countries. Your Dutch BV (besloten vennootschap, the Dutch private limited company) qualifies because it was set up here and is managed from here.

Business profits. A company pays tax on its profit in the country where it is resident. The other country may only tax that profit if the company has a real, lasting presence there. In tax law, this presence is called a permanent establishment. You can read more in when a foreign company becomes taxable in the Netherlands.

Dividends, interest and royalties. For these payments, the treaty has maximum rates. The country where the payment comes from may withhold tax up to that maximum. For dividends from a Dutch BV, the standard Dutch rate is 15%. Under many treaties, the rate is 5%, or zero for company shareholders with a large stake.

Avoiding double taxation. In the last part, the two countries agree what your home country does. Your home country either exempts the income, or it taxes the income and deducts the tax you already paid in the Netherlands.

How to find the rate that applies to you

Follow three steps, in this order.

Step one: check that a treaty is in place. The Netherlands has treaties with almost every country you are likely to trade with. These include China, India, Turkey, Brazil, the United States and all EU member states. The Dutch government publishes the full list. Your adviser can confirm which version applies today.

Step two: find your type of income. Dividends, interest, royalties, salary and business profits each have their own article and their own rate.

Step three: check the conditions. The lower rates usually have conditions. Examples are a minimum shareholding, a minimum holding period, and proof that the receiver is the real owner of the income (the beneficial owner). You claim a treaty rate yourself, and you must show on paper that you meet the conditions.

Why the Dutch network is unusually wide

Around 100 treaties is a large number for a country of this size. The Netherlands has traded internationally for centuries, and the treaty network is a result of this. It is a practical reason why many international groups place a company here. A Dutch company gets a reduced rate on income from most countries in the world.

Two Dutch rules also apply next to the treaties. First, profit that a Dutch holding company receives from a subsidiary is generally free of Dutch corporate tax. This way, the same profit is taxed only once inside the group. Second, the Netherlands applies a zero rate at the border on most interest and royalty payments to other countries. A special rate applies to payments to countries with very low tax. With these rules and the treaty network, a Dutch company is an efficient base for international groups.

Treaty conditions today

In the past, a company could use a treaty almost automatically. Countries have since added a condition to their treaties. Treaty benefits apply when the arrangement has a real business reason. The tax authority can refuse them when the tax benefit was one of the main reasons for the structure.

In practice, your Dutch company needs to be a real company. Decisions are taken here, and the directors really direct the company. The company has an office, its own bank account and its own bookkeeping. You can read more in treaty benefits and substance.

The main points

In a tax treaty, two countries agree who taxes which income. The treaty has a maximum for tax withheld at the border, and your home country gives credit for tax already paid. The Netherlands has about 100 tax treaties. To use one, check which treaty applies and meet its conditions on paper. Your company must also operate from the Netherlands.

See the Dutch holding structure for what you save with a holding above the operating company, and what it involves each year. To keep both companies in good standing, see corporate secretarial services in the Netherlands.

Frequently asked questions

How many tax treaties does the Netherlands have? +

Around 100, covering almost every country a Dutch business is likely to trade with. This network is a practical reason many international groups set up a Dutch company.

Does a treaty apply automatically? +

You claim treaty benefits yourself, and you must meet the conditions. These include the right type of income, any minimum shareholding, and proof that your company is the real owner of the income.

What happens if my country lacks a tax treaty with the Netherlands? +

Dutch national rules then apply, and 15% Dutch dividend tax is withheld on a dividend. Your own country decides under its national rules whether it gives credit for that amount.

Sources Belastingdienst · KVK · wetten.overheid.nl Last updated: 6 October 2026