Netherlands

• CORPORATE INCOME TAX (CIT): The standard rate is 25% (or 20% on taxable profit up to EUR 200,000.)  With Advanced Tax Ruling effective CIT rate can be brought down to 5%.
• INCOMING DIVIDENDS: 0% if Participation Exemption applies.
• CAPITAL GAINS TAX (CGT): 0% if Participation Exemption applies.
• WITHHOLDING TAX:
  ROYALTIES: No withholding tax on royalties
  DIVIDENDS: 0% under EU Parent Subsidiary Directive and/or when participation exemption applies. Withholding tax rate on dividends paid to non-EU entities is 15% unless reduced by the treaty.
  INTERESTS: No withholding tax on interests.
• BILATERAL TAX TREATIES with 95 countries including Hong-Kong, Cyprus, Malta
• VALUE ADDED TAX (VAT). EU VAT regime. The standard rate for inland sales is 21%.

DUTCH BV AS HOLDING COMPANY 

For a long time The Netherlands have been acknowledged as Preferred Holding Jurisdiction as they grasped the idea of elimination of the double taxation on investment profits and  implemented a „participation exemption” or holding regime.

• No minimum holding period
• No corporate tax on dividends arrived to Dutch holding company
• Capital gains on sale of shares are not taxed.

Participation Exemption applies if:

• Dutch Holding Company holds at least 5% of subsidiary’s shares, AND
• Subsidiary is a trading company or subsidiary is not held as a portfolio investment
• OR, Subsidiary is subject to “tax test” – f.e. standard corporate tax rate is at least 10%
• OR, Subsidiary is subject to “asset test” – passive assets must be less than 50%