The Netherlands Increases and Improves its Double Taxation Agreement (DTA) Network

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.