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):
- Cayman Islands
- Isle of Man
- Trinidad & Tobago
- US Samoa
- US Virgin Islands
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.
Moreover, as per 1 januari 2021, a new tax has been introduced in the Netherlands: the so-called conditional 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 21.7% of Dutch withholding tax on those royalty and interest payments.
Jeroen explains more about this new tax law in the video below.