Beneficial owners eligible for tax exemption - Dutch equities (Securities held in CBF)

08.09.2022

The following types of beneficial owner of Dutch equities are recognised for tax purposes in the Netherlands:

  • Residents of Double Taxation Treaty (DTT) countries;
  • EU tax-exempt legal entities.

Residents of Double Taxation Treaty (DTT) countries

Beneficial owners that qualify for the benefit of a reduced rate of withholding tax in accordance with a DTT between their country of residence and The Netherlands. There are no domestic exemptions available for foreign governments or international organisations. Please refer to the relevant DTT where appropriate.Relief at source and quick refund from withholding tax on dividends from Dutch equities may be available if offered by the issuer.

A partial standard refund of withholding tax is available through Clearstream Banking

The customer can reclaim withholding tax on behalf of the beneficial owner through Clearstream Banking by submitting the appropriate documentation.

The maximum rate of withholding tax is defined in the relevant DTT.

EU tax-exempt legal entities

Beneficial owners that:

  •  
  • Are corporate entities established in an EU Member State other than The Netherlands;  and
  • Are not subject to profit tax in their country of residence; and
  • Would not be subject to profit tax if they had been established in The Netherlands.

such as pension funds, charities, etc. and are eligible to a full exemption.

Relief at source and quick refund from withholding tax on dividends from Dutch equities are not available through Clearstream Banking.

A full standard refund of withholding tax is available through Clearstream Banking through the specific EU tax-exempt refund procedure in accordance with the national legislation of The Netherlands

The customer can reclaim withholding tax on behalf of the beneficial owner through Clearstream Banking by submitting the appropriate documentation.

Residents of The Netherlands

Residents of The Netherlands cannot reclaim withholding tax through Clearstream Banking.

Certain Dutch pension funds and Dutch investment funds are entitled under Dutch law to a full refund of withholding tax. As Clearstream Banking does not provide refunds to residents of The Netherlands, they are advised to submit their request directly to the Dutch tax authority.