Intercompany dividend

Is your organisation based outside the Netherlands and does it receive intercompany dividend (participation dividend) from a company based in the Netherlands? In that case, the dividend-paying company usually doesn't have to withhold dividend tax. See Intercompany dividend paid to a shareholder outside the Netherlands (only available in Dutch).

If the dividend-paying company hasn't applied the exemption, your organisation can reclaim the withheld dividend tax if the exemption is based on a tax treaty. The dividend-paying company will then reclaim a dividend tax refund from its tax authorities on behalf of your organisation. This request must be accompanied by certain details. You will find more information on this page under 'Which information must be mentioned in the refund request?'.

If both the withholding exemption under the Dividend Tax Act 1965 and the withholding exemption on the basis of a tax treaty apply, your company is not entitled to a refund. If dividend tax has nevertheless been withheld, your organisation can lodge an objection (only available in Dutch).

Which information must be mentioned in the refund request?

When reclaiming dividend tax on your behalf, the dividend-paying company must mention the following details:

the name, address and place of residence of the recipient of the dividend
the amount of the issued capital (geplaatste kapitaal) and the paid-up capital (gestorte kapitaal) of the Dutch company
the part of the capital of the Dutch company directly or indirectly held by the recipient

The applicable tax treaty can contain further conditions. Depending on the treaty, the dividend-paying company must also mention in the request:

that the recipient's capital is fully or partially divided into shares
that the recipient is not a partnership (maatschap) or general partnership (vennootschap onder firma, vof)
that the dividends will paid in the country of residence of the recipient and, therefore, will be subject to taxation in that country
information on other, not previously mentioned conditions