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
  • 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.