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December 19, 2019

Limitation of holding structures for intra-EU dividends: A blow to tax avoidance?

Publication

This article analyses the recent rulings from the European Court of Justice in two Danish cases and examines their possible impact on international tax avoidance.

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January 24, 2019

Conduit country the Netherlands in the spotlight

Publication

The Netherlands is an important link in the chain of diverting income flows: broader use of withholding taxes is necessary to combat international tax avoidance.

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January 24, 2019

The Netherlands is an important link in the chain of diverting income flows: broader use of withholding taxes is necessary to combat international tax avoidance

Pressrelease

Sixty percent of the royalties that flow via the Netherlands go directly to tax haven Bermuda. Outgoing interest flows are diverted less often to tax havens: around 20 percent. In addition, some 25% of the outgoing interest flows to other conduit countries, such as Ireland, Luxemburg and Switzerland. In addition, a large share of dividends comes from these countries. The conditional withholding tax, planned for 2021, does not stop the financial flows from and to other conduit countries. The reason for this is that the conditional withholding tax only applies to countries with a statutory rate of the corporate income tax of 9 percent or less. That does not include Ireland, Luxemburg and Switzerland.