JJurical
International2 credits

Treaty rate for dividends, interest and royalties — with the thresholds stated

Determine the applicable withholding-tax rate between the Netherlands and 21 treaty countries, for outbound and inbound flows. The tool places the domestic rate next to the treaty rate, tests your holding against the qualifying-participation threshold, and flags where LOB, MLI or an elevated beneficial-ownership risk needs attention.

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treatycalc v1.0.0 · vintage 2026.1 · draft free
Example outcome
Applicable treaty rate5%
Domestic rate — NL outbound dividend15%
Holding 15% — participation threshold met≥ 10%
Netherlands–Germany treaty1959 / 2012
sha256 a3f19c47e8b2d05f6c91a4e7d23b8f50…

Who it’s for

01International tax advisers who need a quick first rate orientation before diving into the treaty text.
02Group tax and tax managers calculating and documenting a dividend, interest or royalty flow inside the group.
03Trust and corporate services offices who must be able to show per entity which rate was applied and on which threshold it rested.

What the tool does

✓ 21 treaty countries versus the Netherlands: DE, FR, BE, LU, UK, SE, DK, ES, IT, IE, CH, US, CA, JP, CN, SG, AU, AE, ZA, KR and HK✓ Three income types: dividends, interest and royalties — outbound (NL pays) and inbound (NL receives)✓ Qualifying-participation rate or portfolio rate depending on your holding versus the treaty threshold; without a holding the tool shows both✓ Flags for holding period, LOB requirement, MLI type and beneficial-ownership risk — as points of attention, not as a test✓ Availability of the Parent-Subsidiary Directive and the Interest & Royalties Directive is reported; the rate shown remains the treaty rate✓ Treaty year per country and the dataset vintage used, in the report, with a verification hash
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.

A rate is only usable with its threshold attached

With withholding tax, the percentage itself is rarely the problem — the condition underneath it is: a qualifying-participation threshold that varies per treaty from 5% to 50%, a holding period of six or twelve months, or an LOB article that makes the benefit depend on who sits behind the company. This tool always places the applicable rate next to the threshold it was tested against and next to the domestic rate the treaty reduces.

Be aware of the limits of the calculation. The model holds one participation threshold with one corresponding rate per country; treaties with more tiers are flattened to that single tier. Holding periods are reported but not tested, and the tool performs no PPT, LOB or beneficial-ownership test — those flags are signalling, not a judgement. The report names the treaty year per country and the dataset vintage used, so you know exactly which table you hold; for a definitive position, always verify against the consolidated treaty text.

Frequently asked questions about this tool

Which countries and payments does the tool cover?
Twenty-one treaties versus the Netherlands — Germany, France, Belgium, Luxembourg, the United Kingdom, Sweden, Denmark, Spain, Italy, Ireland, Switzerland, the United States, Canada, Japan, China, Singapore, Australia, the UAE, South Africa, South Korea and Hong Kong — for dividends, interest and royalties, in both directions. Other countries, other income categories and triangular situations fall outside it.
Does the tool test anti-abuse provisions such as PPT, LOB or beneficial ownership?
No. The tool reports per country the MLI type, whether the treaty has an LOB article, and which beneficial-ownership risk level the dataset records, so you know where to look. The test itself — whether the benefit is actually available in your structure — is substantive work the tool does not perform and does not replace.
How current is the treaty table?
The dataset carries no publication year; it does state the treaty year per country (for example “1959 / 2012” for Germany), and the report names the pinned vintage the calculation used. Treat the outcome as a first orientation and check the rate against the consolidated treaty text before you base a position on it.
Try the draft — free and without an account.
You pay only when you unlock the report.
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Treaty rate for dividends, interest and royalties — with the thresholds stated — Jurical