Changes dividend tax Dutch Cooperative societies (“Coops”)

Jun 8, 2016

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?