Low-tax jurisdictions
The Dutch government published a list of the low-tax jurisdictions that are relevant for taxation in the Netherlands. The list that includes these low-tax jurisdictions is also known as the Dutch blacklist or the blacklisted jurisdictions. The list will be updated annually.
The full list of low-tax jurisdictions that applies in the Netherlands
The 2020 Dutch blacklist list consists of the following countries (in alphabetical order):
- Anguilla
- Bahamas
- Bahrein
- Barbados
- Bermuda
- British Virgin Islands
- Cayman Islands
- Fiji
- Guam
- Guernsey
- Isle of Man
- Jersey
- Palau
- Panama
- Samoa
- Trinidad en Tobago
- Turkmenistan
- Turks- and Caicos Islands
- United Arab Emirates
- US Virgin Islands
- US Samoa
- Vanuatu
The blacklist is of relevance for the application of the Dutch participation exemption. Dutch holding companies with a subsidiary company in a low-taxed jurisdiction may – under circumstance – not be able to benefit from the Dutch participation exemption.
Jeroen explains more about the Dutch participation exemption in the video below.
Recently, Netherlands introduced a withholding tax on interest and royalty payments. This tax works as following: Dutch companies that pay a royalty and/or interest to a related company in a blacklisted country -one of the countries in the list above- may have to withhold 25.8% of Dutch withholding tax on those royalty and interest payments. As of January 1, 2024 the Dutch Withholding Tax AcT law also applies to dividends paid to recipients in low-tax countries in addition to the existing Dividend Tax Act.
Jeroen explains more about this new tax law in the video below.