Amsterdamse gracht

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
  • Bermuda
  • BVI
  • Cayman Islands
  • Fiji
  • Guam
  • Guernsey
  • Isle of Man
  • Jersey
  • Oman
  • Samoa
  • Trinidad & Tobago
  • Turkmenistan
  • Turks-Caicos
  • UAE
  • US Samoa
  • US Virgin Islands
  • 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.

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.