The Dutch tax treaty network

What a treaty does

In a double tax treaty, two countries agree which country may tax which income. This way, the same profit is taxed once. The treaty sets maximum rates for withholding tax on dividends, interest and royalties. National rates are often 15–25%, and treaty rates are often 0–10%. The treaty also states when a business presence in the other country is a permanent establishment. For a company that both countries treat as resident, the treaty has tie-breaker rules. These rules apply to every cross-border payment in your structure.

The Dutch treaty network in 2026

The table is based on the quarterly overview of 1 July 2026 by the Ministry of Finance. It also uses the 2026 treaty letter to parliament.

The Ministry of Finance updates the official overview every quarter. We follow each new edition. You can find the date of the last check with the sources.

What the network means for a holding structure

Three sets of rules apply. Inside the EU, qualifying dividends between group companies have 0% withholding tax under the parent-subsidiary rules. Under the treaties, maximum rates apply to payments to and from treaty countries. These rates are lower than the national rates. Inside the Dutch structure, the participation exemption applies. Dividends and sale proceeds from a shareholding of 5% or more are free of corporate tax. For these reasons, many international groups use a Dutch holding. You can read more about how the holding structure works.

Since 2021 the Netherlands also levies a conditional withholding tax on interest and royalties paid to affiliated companies in listed low-tax jurisdictions. Since 2024 this tax also applies to dividends. The UAE left that list in 2024, after it introduced its own corporate tax of 9%. Bahrain is still on the list. If your group has a company in a listed jurisdiction, plan the structure before incorporation. Arrange real activity in each country (substance) and treaty protection in advance. You can read more in the comparison of the Netherlands and Dubai.

Reading a treaty for your own case

Check three things for your own case. Which withholding rate applies to dividends at your percentage of shares? Is your activity in the other country a permanent establishment? In which country is a company resident when it is managed from more than one country? The Dutch text of every treaty is public. In a written analysis, we apply the treaty to your own numbers.

Frequently asked questions

Is there withholding tax on dividends paid from the Netherlands to the UAE?

Dutch dividend tax is 15%. Dividends to a UAE parent company that owns at least 5% of the Dutch company are exempt. This exemption applies if the structure has valid business reasons that reflect economic reality (Dividend Tax Act 1965, Article 4). Otherwise, the Netherlands-UAE tax treaty applies. The maximum rate is 5% for a company with at least 10% of the capital and 10% in other cases. UAE government bodies named in the treaty pay 0% (Article 10). The conditional withholding tax of 25.8% applies to payments to affiliated companies in listed low-tax jurisdictions and in certain abuse situations. The UAE left that list in 2024.

How many tax treaties does the Netherlands have in 2026?

The Netherlands has tax treaties in force with roughly one hundred countries. In 2026 it negotiates new or updated treaties with twelve countries. Some of them, such as Brazil, Portugal, Romania and New Zealand, already have a treaty with the Netherlands. It signed new treaties with Benin on 21 May 2026 and with Sweden on 24 June 2026. An agreement with Spain is ready for signature. The amended treaty with Germany entered into force on 1 January 2026.

What does a tax treaty do for my company?

A tax treaty sets a maximum rate for withholding tax on dividends, interest and royalties. It sets out when activity in the other country is a taxable permanent establishment. It also states which country a company belongs to when both countries treat it as resident. These rules apply to every cross-border payment in your structure.

Why does the treaty network favour a Dutch holding?

Under the EU parent-subsidiary rules, qualifying dividends paid within the EU have 0% withholding tax. The treaties with roughly one hundred countries set maximum withholding rates. Under the Dutch participation exemption, dividends and sale gains from shareholdings of 5% or more are free of corporate tax.

Does the Netherlands levy withholding tax itself?

Yes. The standard dividend withholding tax is 15%. For qualifying corporate shareholders, treaties and EU rules reduce or remove this tax. A conditional withholding tax applies to payments to affiliated companies in listed low-tax jurisdictions. Check this list before you set up your structure.

Where is the official treaty list published?

The Ministry of Finance publishes the treaty overview (verdragenoverzicht) on Rijksoverheid.nl and updates it every quarter. The Belastingdienst publishes extracts per country. The information here is based on the edition of 1 July 2026.