The Ministry of Finance has announced that they do not see any valid reason for the difference in dividend tax treatment of Dutch limited liability companies such as a N.V. or B.V. (15% dividend withholding tax) compared to Dutch Coops used in international (US) holding structures (generally 0% dividend tax unless in abusive cases). The Cabinet of the Netherlands sees no valid reason for this difference and will issue a proposal to abolish this difference (ultimately per 1 January 2018) on 20 September 2016
It is unclear how the issue will be resolved, i.e. will the proposal lead to Coops having to withhold 15% dividend withholding or will the NV or BV perhaps no longer become subject to dividend withholding tax?