Holding company in the Netherlands: dividend withholding, conditional withholding and Andorra

In brief

The Netherlands is another historic hub for holding companies, known for its treaty network and its participation exemption regime. In recent years the country has tightened its anti-abuse rules: what used to count as a location advantage is now restricted.

The rate

Corporate income tax is 19 %verified on 12/10/2026 on the first 200,000 €verified on 12/10/2026 of profit and 25.8 %verified on 12/10/2026 above that in 2026, under the tax package adopted for this year.

Dividend withholding tax

The domestic dividend withholding rate is 15 %verified on 12/10/2026. Exemptions exist for recipients established in the European Union, the European Economic Area or a treaty country, subject to conditions on shareholding, beneficial ownership and anti-abuse rules.

The conditional withholding tax

The Netherlands applies a conditional withholding tax on dividends, interest and royalties paid to related entities located in low-tax jurisdictions or jurisdictions listed by the European Union. The "low-tax" criterion is a statutory rate below 9 %verified on 12/10/2026. It applies even where a treaty exists. This is a rule to know about if a Dutch structure pays a holding company located in a low-tax country.

The participation exemption

A participation exemption regime exists for dividends and capital gains from qualifying shareholdings, with tests on the holding, the nature of the assets and the motives. The holding threshold is under discussion: an increase has been proposed in Parliament with a phased entry into force, and we have not been able to confirm whether it was adopted. We therefore do not publish a threshold: to be checked with the Dutch tax authority.

Who it suits

The Netherlands suits international groups with varied operating subsidiaries and real activity on the ground. It is poorly suited to a standalone holding company without substance.

Compared with Andorra

Andorra offers a simple statutory rate and participation regime, but a much more limited treaty network. If a Dutch structure pays income to a company in a low-tax country, the conditional withholding tax may apply: the criterion is the statutory rate of the recipient country. For Andorra, the general rate is 10 %verified on 09/10/2026. See the holding company in Andorra.

For a French resident

To verify

The figures on this page come from foreign firms and authorities, verified on 12 October 2026: they are dated in our database and should be confirmed with local advice before any decision. This page is a guide, not tax advice. The participation exemption threshold is deliberately not published here, for lack of official confirmation.

Other countries

Comparison of countries for a holding company, holding company in Andorra, Luxembourg, Malta, Cyprus. Test the Andorran conditions in the holding simulator.