On 10 June 2014, the proposed new bilateral arrangement for the avoidance of double taxation for the Netherlands and Curacao (the “TNC”) was presented to Dutch Parliament. The TNC shall replace the current Tax Arrangement of the Kingdom and is expected to enter into force as per 1 January 2015.
Amongst other things, the TNC introduces a 0% dividend withholding tax rate, albeit under strict conditions. The TNC further includes a beneficial transitional rule under which shareholdings of at least 25% may apply a reduced 5% dividend withholding tax rate (currently 8.3%) until 31 December 2019.