How it works
When a BV pays a dividend, it keeps 15%. Within one month, it pays this to the tax authority with a dividend tax return. The shareholder receives 85%. The 15% is a prepayment. What happens next depends on who the shareholder is.
A Dutch resident with a substantial interest pays box 2 on the full dividend and deducts the 15% already paid. A Dutch holding with 5% or more receives the dividend with 0% withholding, because the participation exemption applies.
A foreign shareholder checks the tax treaty. Under many treaties, the 15% is lowered to 10%, 5% or 0% for a company with a substantial stake. A parent company with 5% or more receives the dividend at 0% if it is based in the EU, the EEA or a country whose tax treaty with the Netherlands covers dividends. The structure must also pass the anti-abuse test: a structure that is artificial and set up to avoid tax fails it. The Netherlands has around 100 tax treaties.
Dutch companies pay interest and royalties abroad free of withholding tax. A conditional withholding tax applies only to payments to listed low-tax countries. Foreign groups put their European holding in the Netherlands partly for these reasons.
Example
A BV pays €100,000 dividend to its Indian parent company. India has a tax treaty with the Netherlands, so the parent company (5% or more) receives the full €100,000 free of Dutch dividend tax, unless the structure is artificial and set up to avoid tax. The treaty rate of 10% applies to the other shareholders, such as a person living in India. The BV then withholds €10,000 and pays €90,000.
The figures
Every rate for 2026 is listed in Netherlands tax rates 2026, and the figures for 2027 are in Netherlands tax rates 2027.
Questions people ask
When is the dividend tax return due?
Within one month after the dividend is made payable. The BV files the return and pays the withheld amount in the same month.
Can a foreign shareholder reclaim withholding tax?
Yes. When the treaty rate is lower than the amount withheld, the shareholder claims the difference from the Dutch tax authority. With the right forms, the BV can withhold at the treaty rate when it pays. The shareholder then avoids the refund process.
Holdwise, Hoofddorp. We keep this definition in line with our Dutch and German glossaries, and the figures are those for the tax year 2026. Updated 30 September 2026.
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