A new double tax treaty with The Netherlands was concluded in September 2019, the provisions of which will take effect on or after 1 January 2021.
The taxes that are covered are as follows: -
- Dividends – the treaty provides for a 15% withholding tax on dividends unless the beneficial owner of the dividend holds at least 5% of the share capital of the dividend paying company for a period of at least one year or the beneficial owner is a recognized pension fund.
- Interest and Royalties – there is no withholding tax on interest and royalties as far as the recipient is the beneficial owner of the income.
- Capital gains – gains from the sale of shares of companies are taxed in the country where the seller is located, except in the case of sale of shares of immovable property companies, where the tax is levied in the country where the immovable property is located.