Dutch withholding taxes: 15% dividend tax, conditional tax and Gulf treaty rates

Country reference

• Country: Netherlands (planned expansion country)
• Authorities: Ministry of Finance; Netherlands Tax Administration (Belastingdienst)
• Topic: Dividend withholding tax and conditional withholding tax
• Key date: Rates for 2026; the Dutch low-tax list is updated each year
• Law: Dividend Tax Act 1965; Withholding Tax Act 2021

Dividend withholding tax

• 15% on dividends from Dutch resident companies.
• Exemption for EU, EEA and treaty-country shareholders that would qualify for the participation exemption if Dutch, subject to anti-abuse rules.
• Business-driven cooperatives generally fall outside.

Conditional withholding tax

• Applies to interest, royalties and dividends paid to affiliated entities in jurisdictions with a statutory rate below 9% or on the EU non-cooperative list, and in abusive cases.
• Rate equals the top corporate rate: 25.8% in 2026.
• The Dutch list is updated each year and applies from the following 1 January.

Gulf position

• The UAE was removed from the Dutch list from 2024 after it introduced 9% corporate tax; Bahrain remained on the 2024 list, according to adviser reports.
• PwC’s 2026 summary still shows the UAE on its combined list, so confirm the current official list before paying interest, royalties or dividends.
• Treaty rates (dividends/interest/royalties): UAE 5 or 10%/0%/0%; Saudi Arabia 5 or 10%/0 or 5%/7%; Qatar 0 or 10%/0%/5%, per PwC.

What to do now

• Map payments from Dutch entities to Gulf affiliates.
• Hold treaty residence certificates and substance evidence.
• Check the list update each autumn for the coming year.

Our take

The list decides whether a 25.8% tax applies, so it is worth checking every year. Bahrain-based structures, and any UAE structure until the current list is confirmed, need careful review.