Netherlands – Germany :New Tax Treaty Enters Into Force

The new Income Tax Treaty between the Netherlands and Germany has entered into force today, 1 December 2015.

The new Treaty generally applies from 1 January 2016 and replaces the old treaty of 1959.

In accordance with the new treaty, the following withholding taxes will apply:

Dividends:

• 5% if the beneficial owner is a company (other than a partnership) which holds directly at least 10% of the capital of the company paying the dividends.
• 10% if the beneficial owner is a pension fund resident in the Netherlands.
• 15% in all other cases.

Interest: 0%.

Royalties: 0%.