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Written by:
Bas Hollenberg


Withholding Tax Act 2020: second memorandum of amendment

The Withholding Tax Bill 2020 by means of a second memorandum of amendment has been renamed the Business and Industry Bill 2019. The memorandum of amendment comprises the following measures:

  • elimination of the dividend tax abolition,
  • non-introduction as at the first of January 2020 of withholding tax on dividends to tax havens and in abuse scenarios,
  • elimination of the ban on investment in REITS in a corporation tax sphere,
  • further reduction of the higher corporation tax rate to 20.5 percent by 2021,
  • further reduction of the lower corporation tax rate to 15 percent by 2021,
  • transitional measure for curbing depreciation on buildings in a corporation tax sphere.

The (lower and higher) corporation tax rates will amount to 19 and 25 percent in 2019, against 16.5 and 22.55 percent in 2020 and 15 and 20.5 percent from 2021 onwards.

The transitional measure regarding depreciation of proprietarily used buildings in a corporation tax sphere applies to buildings having been involved in depreciation prior to the first of January 2019, but for fewer than three full years. The limitation of depreciation to 100 percent of the value for the purpose of the Valuation of Immovable Property At of the Netherlands will not apply throughout the relevant period.

Read more: Dividend withholding tax proposal nixed: substitute propositions

Relevant articles:

Dutch version: Tweede nota van wijziging Wet Bronbelasting 2020


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