JJurical
Dividend tax1 credit

Dividend withholding tax on outbound distributions — exemption, treaty rate or 15%

Establish which rate of Dutch dividend withholding tax applies to a distribution: the exemption of Art. 4 Wet DB 1965, a treaty rate from the 42 countries in the dataset, or the standard 15%. With a conditions check on shareholding, country of residence, holding period, substance and anti-abuse, and a gross-to-net calculation on the amount you enter.

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dividendbelasting-toets v1.0.0 · vintage 2026.1 · draft free
Example outcome
Withholding tax rate2.5%
Route — exemption denied, NL-LU treaty rate25% stake
To withhold — on € 100,000 gross dividend€ 2,500
Points of attention — conduit, PPT, substance3 flags
sha256 a3f19c47e8b2d05f6c91a4e7d23b8f50…

Who it’s for

01International tax advisers who must establish the withholding percentage per distribution and want the conditions on file.
02Trust and corporate service providers who want to know for a holding structure where the exemption does and does not hold.
03CFOs of international groups who want the net proceeds of a distribution to the parent before deciding.

What the tool does

✓ Five outcomes: exemption at 0%, a treaty rate, the standard 15%, a resident shareholder with credit, or not applicable✓ A treaty table of 42 countries, each with its standard rate, participation rate and the shareholding threshold that applies✓ A six-point conditions check: legal form, a shareholding of at least 5%, country of residence, holding period, substance and the anti-abuse criterion✓ Per-country points of attention from the dataset — conduit, LOB clause, substance, PPT, beneficial owner and sanctions risk✓ A gross-to-net calculation: the tax to withhold and the net distribution on the gross dividend you enter✓ A documentation checklist and the legal basis per outcome, ready to add to the file
01 — Form
Case and key figures — a handful of fields.
02 — Draft
Full outcome layout, free.
03 — Pay and receive
Via Mollie, VAT/VIES handled.
04 — Report
Certified PDF + public hash.

The exemption is a set of conditions, not a switch

The withholding exemption asks for more than a 5% stake in an EU or treaty country. Holding period, substance at the recipient and whether the structure is primarily tax-driven all bear on whether the exemption holds — and those are precisely the points an inspector looks at. The check works through them one by one and records per condition whether it is met, needs attention or fails, so the substantiation is not a single yes or no.

If the exemption does not hold, the treaty is the next layer: many treaties carry a reduced participation rate above a given stake and a higher standard rate below it. The tool looks up both per country, applies the right rate to your shareholding and states the treaty basis alongside. Every report records the route taken, the rates used, the tool version and the dataset vintage, so the outcome stays traceable — including when a treaty is later amended.

Frequently asked questions about this tool

Is this the same test as the distribution test of Art. 2:216 BW?
No, that is a different question and a different tool. This test concerns the withholding tax on a distribution. The distribution test concerns whether the company is permitted to distribute at all under corporate law: the balance sheet and liquidity tests the board must perform. For an outbound distribution you usually need both.
Why does the treaty rate depend on my shareholding?
Because many treaties carry two rates: a reduced participation rate once the stake exceeds a threshold named in that treaty, and a higher standard rate below it. That threshold differs per country — sometimes 5%, sometimes 10%, sometimes 25% or more. The tool compares your stake with the selected country’s threshold and shows which of the two rates is applied.
What happens if I answer that the structure is tax-driven?
The exemption is denied and the calculation falls back to the treaty rate of the selected country. In some treaties that participation rate is low or even zero, so the outcome can still look favourable while the anti-abuse flag stands. Read that outcome carefully: in practice an anti-abuse problem usually affects treaty benefits too, and the tool does not model that.
How current is the treaty table?
The table comes from the dataset vintage stated in the report and carries no official as-of date. Several treaties included are old and some have since been amended by protocols; the report warns about that too. Check the applicable treaty and its protocols with the Dutch government before using the percentage for a filing.
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You pay only when you unlock the report.
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Dividend withholding tax on outbound distributions — exemption, treaty rate or 15% — Jurical