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Netherlands issues favorable withholding tax Decree dealing with disregarded entities

|Tax Alerts, Legislation & Policy, National/Federal Taxation, Treaties|United States, Netherlands
United States, Netherlands

  • On 6 December 2022, the Dutch State Secretary of Finance published a Decree regarding the application of the Dutch hybrid provisions in the Dutch Dividend Withholding Tax Act 1965 (DWHTA) and the Conditional Withholding Tax Act 2021 (CWHTA).

  • The new Decree provides favorable guidance for scenarios involving a Dutch disregarded entity (withholding agent) making a payment of dividends, interest or royalties to another hybrid entity.

Executive summary

The hybrid entity rules included in the DWHTA and …

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