Dutch Shell Companies and International Tax Planning
These flows come from Ireland, Singapore and the United States. For dividend and interest payments the geographical pattern is more widespread.
We find a substantial tax reduction for royalties by using Dutch SPEs compared to a direct flow between the origin and destination country. However, we cannot find such tax savings for dividends and interest with an approximation based on statutory tax rates.
This Discussion Paper reports research on the financial flows already presented in the CPB Policy Brief of 24 January 2019: Conduit country the Netherlands in the spotlight.