The Netherlands has more
than 100 tax agreements and continues negotiating to add more treaties to its
network.
It is currently negotiating
to improve the protocols of the agreements signed with Belgium, Canada and
Bulgaria. Besides, it has offered to
include anti abuse clauses to its tax treaties with Bangladesh, Egypt, Ethiopia,
the Philippines, Georgia, Ghana, India, Indonesia, Kenia, Malawi, Morocco,
Moldova, Mongolia, Nigeria, Pakistan, Sri Lanka, Uganda, Ukraine, Uzbekistan,
Vietnam, Zambia and Zimbabwe.
The new DTA with China entered into forced on August
31 2014, after several months re-negotiating the 1988 agreement. The new agreement, that entered into forced as
of January 1 2015, offers a simpler way to structure investment going into
China from The Netherlands; using The Netherlands as the gateway of Chinese
investment in Europe. Among the new
treaty clauses are measures that allow for the distribution of dividends to a
holding company resident in the other state at a reduced rate of 5% when the
participation of the holding company on the subsidiary is equal or greater than
25%. Besides, the agreement adds
anti-abuse provisions and foresees an exchange of information based on the OECD
model to avoid tax evasion.
