Tackling tax avoidance

Preventing abuse of the tax system

Central government has introduced measures specifically aimed at combating tax avoidance and tax evasion. For example: 

• In 2019 some €37 billion in interest, royalties and dividend payments flowed to low-tax countries via the Netherlands. These are countries that levy no tax on profit or too little (less than 9%). In 2021 the Netherlands began levying tax on interest and royalty payments made by one company to another company that belongs to the same group and is established in a low-tax country. The withholding tax rate is equal to the top rate of corporation tax (currently 25.8%). Since 2024 dividends have also been subject to the withholding tax. The flow of interest, royalties and dividends to low-tax countries dropped to €6.5 billion.
• The Multilateral Instrument (MLI) enables the Netherlands to amend tax treaties with a large group of countries simultaneously, and without negotiations, in order to combat tax avoidance. The Netherlands takes a stricter line in this respect than many other countries.

Increasing transparency and integrity

Central government has also introduced general measures to prevent tax avoidance. For example:

• The Netherlands has its own list of low-tax countries. The Netherlands uses this list when applying various measures, such as withholding tax on interest and royalties.
• As of 1 January 2021, tax advisers, accountants and financial institutions are required to report potential undesirable tax arrangements to the Dutch Tax Administration. This information is automatically exchanged with other tax administrations in the EU. 
• More international guidelines for exchanging information are in the pipeline. As of 1 January 2023, digital platforms are required to provide tax information on sellers to a tax administration in an EU member state. The tax administrations of the member states share this information with each other (in Dutch) so that they know what their residents are earning via digital platforms. The tax authorities can use this information for taxation purposes.

Crypto service providers required to share client information with Tax Administration

The government has proposed legislation requiring Dutch providers of crypto services to furnish the Tax Administration with information about their clients (including citizen service numbers (BSN) and home addresses) and their clients’ crypto transactions, as of 1 January 2026. The Tax Administration will also receive information from providers in other EU countries about transactions by Dutch citizens. This is set out in the bill implementing the EU directive on the exchange of information on crypto-assets (in Dutch) which has yet to be considered by the House of Representatives and the Senate.
The bill lays down national rules implementing the amendment to the EU directive on administrative cooperation in the field of taxation. This amendment, also known as DAC8, contains rules on exchanging information about crypto-assets. The proposed legislation will ensure that the Tax Administration has a better picture of crypto-asset transactions and is able to identify people who try to avoid taxation on such transactions. The measures in this bill will not change anything for owners of crypto-assets. Crypto-asset owners are already required to declare them in their tax return (in Dutch).

After the bill has been considered by both houses of parliament in early 2026, it will become law. When it enters into force, the new law will apply retroactively from 1 January 2026. From that date, crypto service providers can start requesting and reporting information.