Treaty countries
This table lists:
- the countries with which the Netherlands has concluded a treaty on the exemption from/refund of dividend tax
- the percentage of the gross dividend for which an entitlement to an exemption or refund exists with respect to investment dividends
- the period in years within which the request for a refund must have been submitted
|
Treaty country |
% exemption or refund |
Period (years) |
|---|---|---|
|
Albania (7, 11) |
0% |
3 |
|
Argentina (5, 11) |
0% |
3 |
|
Armenia |
0% |
3 |
|
Australia |
0% |
3 |
|
Austria (16) |
0% |
5 (20) |
|
Azerbaijan (19) |
5% |
5 |
|
Bahrain (21) |
5% |
3 |
|
Bangladesh |
0% |
4 |
|
Barbados* (17) |
0% |
3 |
|
Belarus |
0% |
3 |
|
Belgium (6) |
0% |
5 (20) |
|
Brazil |
0% |
5 |
|
Bulgaria |
0% |
5 (20) |
|
Canada |
0% |
3 |
|
China (19) |
5% |
5 |
|
Croatia |
0% |
3 |
|
Czech Republic (19) |
5% |
5 (20) |
|
Denmark |
0% |
5 (20) |
|
Egypt |
0% |
3 |
|
Estonia |
0% |
5 (20) |
|
Finland (17) |
0% |
5 |
|
France (7) |
0% |
5 (20) |
|
Georgia (22) |
0% |
3 |
|
Germany |
0% |
5 |
|
Ghana* (13) |
5% |
3 |
|
Greece |
0% |
5 (20) |
|
Great Britain and Northern Ireland (23) |
5% |
5 |
|
Hungary |
0% |
5 |
|
Hong Kong (15, 24) |
5% |
3 |
|
Ireland* (8) |
0% |
6 |
|
Iceland |
0% |
3 |
|
India (19) |
5% |
3 |
|
Indonesia (19) |
5% |
3 |
|
Israel* |
0% |
5 |
|
Italy |
0% |
5 |
|
Japan* (25) |
5% |
5 |
|
Jordan (11) |
0% |
3 |
|
Kazakhstan |
0% |
3 |
|
Kuwait (9) |
5% |
3 |
|
Korea |
0% |
5 |
|
Latvia |
0% |
5 (20) |
|
Lithuania |
0% |
5 (20) |
|
Luxembourg |
0% |
5 (20) |
|
Macedonia |
0% |
3 |
|
Malaysia* (7) |
0% |
3 |
|
Malta* |
0% |
5 (20) |
|
Morocco |
0% |
3 |
|
Mexico (12) |
0% |
3 |
|
Moldavia |
0% |
3 |
|
Mongolia (11, 28) |
0% |
5 |
|
New Zealand |
0% |
5 |
|
Nigeria (10) |
0% |
3 |
|
Norway (27) |
0% |
5 |
|
Oman (18) |
5% |
5 |
|
Pakistan |
0% |
3 |
|
Panama (15) |
0% |
3 |
|
Philippines |
0% |
2 |
|
Poland |
0% |
5 (20) |
|
Portugal (19) |
5% |
5 (20) |
|
Qatar (14) |
5% |
5 |
|
Romania |
0% |
5 (20) |
|
Russian Federation |
0% |
2 |
|
Saudi Arabia (21) |
5% |
5 |
|
Singapore (7) |
0% |
3 |
|
Slovenia (17) |
0% |
5 (20) |
|
Slovakia (19) |
5% |
5 (20) |
|
South Africa (4) |
5% |
3 |
|
Soviet Union (2) |
0% |
5 |
|
Spain |
0% |
5 (20) |
|
Sri Lanka |
0% |
3 |
|
Surinam |
0% |
5 |
|
Sweden |
0% |
5 (20) |
|
Switzerland (17) |
0% |
5 |
|
Taiwan (3, 19) |
5% |
5 |
|
Thailand* |
0% |
3 |
|
Tunisia |
0% |
3 |
|
Turkey |
0% |
5 |
|
Uganda (17) |
0% |
5 |
|
Ukraine |
0% |
3 |
|
United Arab Emirates (26) |
5% |
3 |
|
Uzbekistan |
0% |
3 |
|
Venezuela (19) |
5% |
2 |
|
Vietnam |
0% |
3 |
|
Yugoslavia (former) (1) |
0% |
5 |
|
Zambia (7) |
0% |
6 |
|
Zimbabwe (7) |
0% |
3 |
* The Convention with this country includes a ‘remittance-base’ provision. If that provision is applicable to the resident of that country in question, he or she should not use form IB 92 Universal but form IB 93 Universal for the dividend tax refund, if there is entitlement to that refund.
- The convention applies to Bosnia-Herzegovina and the Federal Republic of Yugoslavia (Montenegro and Serbia, including Kosovo).
- The convention applies to the former regions of the Soviet Union other than the former regions of the Soviet Union to which a new convention already applies.
- On 27 February 2001 an ‘Agreement for the avoidance of double taxation’ was entered into between the Taipei Representative Office in the Netherlands and the Netherlands Trade and Investment Office in Taipei. This agreement is not a formal tax agreement, but both countries regard it as being a tax agreement.
- For exempted pension funds, natural persons or bodies other than pension funds, the convention percentage for the proceeds of shares, profit-sharing certificates and profit-sharing bonds is 10% and the exemption/refund percentage 5%.
- For the proceeds of profit-sharing bonds the convention percentage is 12% and the exemption/refund percentage 3%. For the proceeds of shares and profit-sharing certificates the convention percentage is 15% and the exemption/refund percentage 0%.
- For the proceeds of profit-sharing bonds paid to a non-natural person, including pension funds, the convention percentage is 10% and the exemption/refund percentage 5%. For the proceeds of shares and profit-sharing certificates the convention percentage is 15% and the exemption/refund percentage 0% both for non-natural persons and natural persons.
- For the proceeds of profit-sharing bonds the convention percentage is 10% and the exemption/refund percentage 5%. For the proceeds of shares and profit-sharing certificates the convention percentage is 15% and the exemption/refund percentage 0%.
- For the proceeds of profit-sharing bonds the convention percentage is 0% and the exemption/refund percentage 15%. For the proceeds of shares and profit-sharing certificates the convention percentage is 15% and the exemption/refund percentage 0%.
- For the proceeds of shares, profit-sharing certificates and profit-sharing bonds the convention percentage is 10% and the exemption/refund percentage 5%. For persons with a place of residence in Kuwait and in a third-country, the convention percentage is 25% and the exemption/refund percentage 0%.
- For the proceeds of profit-sharing bonds the convention percentage is 12.5% and the exemption/refund percentage 2.5%. For the proceeds of shares and profit-sharing certificates the convention percentage is 15% and the exemption/refund percentage 0%.
- For exempted pension funds in Argentina, Jordan and Mongolia, the convention percentage is 0% for the proceeds of shares, profit-sharing certificates and profit-sharing bonds and the exemption/refund percentage is 15%. For exempted pension funds in Albania the convention percentage is 0% and the exemption/refund percentage 15% for the proceeds of shares and profit-sharing certificates, and for the proceeds of profit-sharing bonds the convention percentage is 10% and the exemption/refund percentage 5%. For natural persons or bodies other than pension funds, the convention percentage is 15% and the exemption/refund percentage 0% for Jordan and Mongolia.
- For exempted pension funds, for the proceeds of profit-sharing bonds the convention percentage is 0% and the exemption/refund percentage 15%. For the proceeds of profit-sharing bonds enjoyed by natural persons or bodies other than pension funds, the convention percentage is 15% and the exemption/refund percentage 5% and 10% respectively and the exemption/refund percentage 10% and 5% respectively in the cases provided for in article 11, paragraph 2a or article 11, paragraph 3a of the Convention. For the proceeds of shares and profit-sharing certificates the convention percentage is 15% and the exemption/refund percentage 0%.
- For the proceeds of shares, profit-sharing certificates and profit-sharing bonds the convention percentage is 10% and the exemption/refund percentage 5%. For exempted pension funds, for the proceeds of shares, profit-sharing certificates and profit-sharing bonds the convention percentage is 0% and the exemption/refund percentage 15%.
- For exempted pension funds and collective investment funds, for the proceeds of shares, profit-sharing certificates and profit-sharing bonds the convention percentage is 0% and the exemption/refund percentage 15%. For natural persons or bodies other than pension funds, the convention percentage is 10% and the exemption/refund percentage 5% for the proceeds of shares and profit-sharing certificates, and for the proceeds of profit-sharing bonds the convention percentage is 0% and the exemption/refund percentage 15%.
- For exempted pension funds and governmental bodies within the meaning of article 10, paragraph 3d of the Convention, the convention percentage is 0% for the proceeds of shares, profit-sharing certificates and profit-sharing bonds and the exemption/refund percentage is 15%. For the proceeds of profit-sharing bonds the convention percentage is 5% and the exemption/refund percentage 10%. For the proceeds of shares and profit-sharing certificates the convention percentage is 15% and the exemption/refund percentage 0%.
- For the proceeds of profit-sharing bonds the convention percentage is 0% and the exemption/refund percentage 15%. For the proceeds of shares and profit-sharing certificates the convention percentage is 15% and the exemption/refund percentage 0%.
- For exempted pension funds, for the proceeds of shares, profit-sharing certificates and profit-sharing bonds the convention percentage is 0% and the exemption/refund percentage 15%. For natural persons or bodies other than pension funds, the convention percentage is 15% for the proceeds of shares, profit-sharing certificates and profit-sharing bonds and the exemption/refund percentage is 0%.
- For pension funds and governmental bodies within the meaning of article 10, paragraph 4 of the Convention, the convention percentage is 0% for the proceeds of shares, profit-sharing certificates and profit-sharing bonds and the exemption/refund percentage is 15%. For the proceeds of shares and profit-sharing certificates the convention percentage is 10% and the exemption/refund percentage 5%. For the proceeds of profit-sharing bonds the convention percentage is 0% and the exemption/refund percentage 15%.
- For the proceeds of shares, profit-sharing certificates and profit-sharing bonds the convention percentage is 10% and the exemption/refund percentage 5%.
- For the Member States of the European Union with which the Netherlands has entered into a tax convention in which a prescription period of less than five years has been agreed, a term of five years should be operated for the refund of deducted dividend tax pursuant to paragraph 6, section 3, of the Decision of 16 December 2010, No. DGB2010/6799M, Government Gazette 2010, 2099.
- For the proceeds of shares and profit-sharing certificates the convention percentage is 10% and the exemption/refund percentage 5% for Saudi Arabia and Bahrain. For the proceeds of profit-sharing bonds the convention percentage is 5% and the exemption/refund percentage 10% for Saudi Arabia, and the convention percentage is 0% and the exemption/refund percentage 15% for Bahrain. For exempted pension funds in Bahrain, for the proceeds of shares, profit-sharing certificates and profit-sharing bonds the convention percentage is 0% and the exemption/refund percentage 15%. This general exemption or refund of Dutch dividend tax is applicable pursuant to article 10, paragraph 10 of the Convention, even if the recipient of the dividends:
- is the Bahraini government or a Bahraini state company;
- a listed company; or
- is running an active company. - For the proceeds of profit-sharing bonds the convention percentage is 0% and the exemption/refund percentage 15%. For exempted pension funds, for the proceeds of profit-sharing bonds the convention percentage is 0% and the exemption/refund percentage 15%. For the proceeds of shares and profit-sharing certificates the convention percentage is 15% and the exemption/refund percentage 0%.
- For the proceeds of shares, profit-sharing certificates and profit-sharing bonds the convention percentage is 10% and the exemption/refund percentage 5%. For exempted pension funds, for the proceeds of shares, profit-sharing certificates and profit-sharing bonds the convention percentage is 0% and the exemption/refund percentage 15%.
- For the proceeds of shares and profit-sharing certificates the convention percentage is 10% and the exemption/refund percentage 5%. For the proceeds of profit-sharing bonds the convention percentage is 0% and the exemption/refund percentage 15%. For exempted pension funds and governmental bodies within the meaning of article 10, paragraph 3 in conjunction with article 11, paragraph 1, of the Convention, the convention percentage is 0% for the proceeds of shares, profit-sharing certificates and profit-sharing bonds and the exemption/refund percentage 15%.
- For the proceeds of shares, profit-sharing certificates and profit-sharing bonds the convention percentage is 10% and the exemption/refund percentage 5%. For exempted pension funds, for the proceeds of shares, profit-sharing certificates and profit-sharing bonds the convention percentage is 0% and the exemption/refund percentage 15%.
- For exempted pension funds, for the proceeds of shares, profit-sharing certificates and profit-sharing bonds the convention percentage is 0% and the exemption/refund percentage 15%. For natural persons or bodies other than pension funds, the convention percentage is 10% and the exemption/refund percentage 5% for the proceeds of shares and profit-sharing certificates, and for the proceeds of profit-sharing bonds the convention percentage is 0% and the exemption/refund percentage 15%.
- For pension funds and government bodies as referred to in Article 10, fourth paragraph, of the Treaty, the income from shares, profit-sharing certificates and profit-sharing bonds the treaty percentage is 0% and the exemption/refund percentage is 15%.
- The treaty between the Netherlands and Mongolia ceased to have effect on 1 January 2014 (Treaty Series 2013, 33).
Intercompany dividends
Form IB 92 Universal should not be used to obtain a (partial) exemption or refund of Dutch dividend tax or intercompany dividends. Intercompany dividends are generally at issue in cases where a foreign company limited by shares directly owns at least 5%, 7.5%, 10%, 15%, 25%, 30%, 50% or another percentage of the capital of a Dutch company. Where references is made to ‘intercompany dividends’, this refers at all times to dividends from a company that at least meets the minimum set in the relevant tax convention. With the exception of the Tax Regulations for the Kingdom (BRK) and the tax conventions with Luxembourg and Singapore, the use of a form is not prescribed to obtain this (partial) exemption. The interested foreign company can apply to the Dutch company that pays the dividend and which submits the application for exemption or refund to the inspector of the organisational unit of the Tax Administration to which it is accountable.
