Netherlands: New Tax Arrangement Between Netherlands And Curacao Looms

The Dutch Lower House (2e Kamer) approved earlier this month the new bilateral rules for the avoidance of double taxation between the Netherlands and Curacao.

This new tax arrangement replaces the current tax arrangement for the Kingdom of The Netherlands.

Next step will be approval by the Upper House (1e Kamer). Provided that all formalities will be met in time, it is exepected that the new arrangement will enter into force on 1 January 2016.

For Curacao entities holding at least 10% of the shares in a Dutch subsidiary, the dividend withholding tax on dividends paid from the Netherlands to Curacao, can be reduced to 0% in certain circumstances, for example in case the Curacao company has sufficient substance on the island.

For multinationals who expect considerable dividend streams from the Netherlands, this new tax arrangement could be very interesting.