News item | 27-06-2025 | 13:36
The government is looking at possibilities to further tighten the approach to dividend stripping. Research has been done on this in the past period. The investigation shows 4 possible measures, which the government wants to bring in internet consultation later this year. After the consultation, it will be decided whether new legislation will be proposed.
The approach to dividend stripping has been intensified since the end of 2023. The Tax and Customs Administration is strictly acting against cases of dividend stripping. However, dividend stripping is very complex and has many forms, which means that the approach to dividend stripping is not easy. That is why the previous cabinet introduced new measures by 2024 and has been investigated in the past period whether more measures are possible. This study also looked at what the Netherlands can learn from other countries. The investigation shows 4 possible measures.
The 4 possible measures will be further elaborated in the coming period. This also takes into account important aspects, such as feasibility, limiting the impact on regular exhibition trade, consequences for citizens and companies and compatibility with European law and tax treaties. The 4 measures will be brought into internet consultation next fall. After the consultation, the measures are weighed and the government decides whether new legislation is being proposed.
The 1st measure focuses on the so -called net return approach. With this measure, it is prevented that someone receives an allowance in the dividend tax, while the return on the shares actually does not or hardly end up with that person. We can work with a so -called efficiency threshold, with which many situations in which the risk of dividend stripping is limited from the measure can be excluded.
The 2nd measure focuses on combating dividend stripping through pension funds. Pension funds can be used to obtain an allowance in the dividend tax for the actual shareholder who has no or less entitlement to that allowance. With this measure, a pension fund is no longer entitled to an exemption or refund of dividend tax if the dividend belongs to a business activity that is not related to normal activities as a pension fund.
The 3rd measure comes from the research into surrounding countries. This study shows that Germany and Austria have a measure to combat dividend stripping, which also seems to be composable in the Netherlands. In both countries, someone is only entitled to a contribution in the dividend tax, if the person really bears the economic risk of the shares over a certain period. It is further investigated whether and how such a measure can be integrated into the Dutch system.
The 4th measure is about clarifying the rules concerning group structures, making it clearer what is and is not allowed.
Follow-up
The 4 possible measures will be further elaborated in the coming period. This also takes into account important aspects, such as feasibility, limiting the impact on regular exhibition trade, consequences for citizens and companies and compatibility with European law and tax treaties. The 4 measures will be brought into internet consultation next fall. After the consultation, the measures are weighed and the government decides whether new legislation is being proposed.