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Financial administration & outsourcing
Entrepreneurs who outsource financial administration reduce the number of administrative tasks and consequently have more time and space to focus on growth.
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Financial insight
We help you turn financial data into valuable insights that support you in making well-founded decisions. In-depth analyses of your financial situation will help give you a better idea of where you stand and where the opportunities for growth lie, both in the short and long term.
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Financial compliance
We make sure your company complies with financial legislation and regulations, with correct financial statements, tax reports and other obligations. From our global network, we support you in managing local and international tax risks.
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Impact House by Grant Thornton
Building sustainability and social impact. That sounds good. But how do you go about it in the complex world of stakeholders, regulations and frameworks and changing demands from clients and society? How do you deal with important issues such as climate change and biodiversity loss?
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Business risk services
Minimize risk, maximize predictability, and execution Good insights help you look further ahead and adapt faster. Whether you require outsourced or co-procured internal audit services and expertise to address a specific technology, cyber or regulatory challenge, we provide a turnkey and reliable solution.
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Cyber risk services
What should I be doing first if my data has been kidnapped? Have I taken the right precautions for protecting my data or am I putting too much effort into just one of the risks? And how do I quickly detect intruders on my network? Good questions! We help you to answer these questions.
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Deal advisory
What will the net proceeds be after the sale? How do I optimise the selling price of my business or the price of one of my business activities?
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Forensic & integrity services
Do you require a fact finding investigation to help assess irregularities? Is it necessary to ascertain facts for litigation purposes?
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Valuations
Independent and objective valuations tailored for mergers, acquisitions, and legal matters.
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Auditing of annual accounts
You are answerable to others, such as shareholders and other stakeholders, with regard to your financial affairs. Financial information must therefore be reliable. What is more, you want to know how far you are progressing towards achieving your goals and what risks may apply.
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IFRS services
Financial reporting in accordance with IFRS is a complex matter. Nowadays, an increasing number of international companies are becoming aware of the rules. But how do you apply them in practice?
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ISAE & SOC Reporting
Our ISAE & SOC Reporting services provide independent and objective reports on the design, implementation and operational effectiveness of controls at service organizations.
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National tax advice
Looking for tax advice in the Netherlands? We help business owners with tailor-made tax advice: from structure and compliance to innovation and sustainability.
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International tax advice
Plan to do business abroad? Our international tax advice helps you with structure and compliance, as well as offering new opportunities. Strategic, practical, and future-oriented.
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Private wealth services
Our Private Wealth specialists offer strategic and practical solutions. From tax advice to estate planning and financial scenarios, we make sure you make the right choices today, for tomorrow.
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Corporate Law
From the general terms and conditions to the legal strategy, these matters need to be watertight. This provides assurance, and therefore peace of mind and room for growth. We will be pro-active and pragmatic in thinking along with you. We always like to look ahead and go the extra mile.
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Employment Law
What obligations do you have with an employee on sick leave? How do you go about a reorganisation? As an entrepreneur, you want clear answers and practical solutions to your employment law questions. At Grant Thornton, we are there for you with clear advice, from contracts and terms of employment to complex matters such as dismissal or reorganisation.
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Sustainable legal
At Grant Thornton, we help companies integrate sustainability into their business operations, with sustainable legal at the heart of our approach. We advise on ESG (Environmental, Social, Governance) legislation, and help draft sustainable contracts, implement HR policies, and carry out ESG due diligence in M&A transactions (Mergers and Acquisitions).
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HR Services
HR is not an aspect of secondary relevance, rather a strategic factor for success. Yet many organisations struggle with issues regarding personnel policy, absenteeism, terms of employment and legislation and regulations.
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Payroll & wage tax
Payment of salaries is not a simple calculation. Laws and regulations constantly change, and mistakes can quickly cause employees to be dissatisfied or lead to tax risks.
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Compensation and benefits
The labour market is changing rapidly. Employees want flexibility, a sense of purpose and a good mixture of financial and non-financial benefits.
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Pension advisory services
Pension is more than an obligation. It is a strategic term of employment that touches upon your employer brand, financial scope and responsibility to provide for your employees.
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Global mobility services
How can you build and evolve a smart global mobility strategy, with policies and processes addressing the complex challenges of managing an international workforce?
When does relief of dividend withholding tax apply?
Dividend withholding tax is levied on the person who is entitled to the proceeds from shares in, profit-sharing certificates from, and certain capital contributions and loans to companies established in the Netherlands.
Dividend withholding tax is withheld by companies established in the Netherlands that distribute profits. The Dutch dividend withholding tax, and personal and corporate income tax provide various options for the recipient of the dividends to credit, recover or reduce the dividend withholding tax withheld, or to obtain a dividend withholding tax exemption. For the application of this relief it is required that the recipient of the dividends is the ultimate beneficiary.
Mainly foreign shareholders benefit
Practice has shown that mainly foreign shareholders are able to reduce Dutch dividend withholding tax through a set of transactions, while they would otherwise not be entitled to such relief. These cases may constitute dividend stripping.
What is dividend stripping?
Dividend stripping involves splitting the legal and economic ownership of dividends to achieve tax benefits. This works as follows:
- A (foreign) shareholder, who is not entitled to an exemption, credit, reduction or refund of dividend withholding tax, retains the economic entitlement to the proceeds of the shares, while transferring the legal ownership of the shares to another party who can claim relief.
- After the dividend has been distributed, ownership of the shares will be transferred back to the original shareholder. The received dividend will then also be transferred to the original shareholder. This construction allows shareholders who do not meet the requirements for dividend withholding tax relief to still benefit this. In this way, the dividend withholding tax can be reduced or even avoided all together.
Record date
One of the measures in this proposal is the introduction of a record date. The record date of a share is the date on which a company determines at the end of the business day which shareholders are entitled to the proceeds from those shares.
The ‘Collective Decree Dividend withholding Tax’ stipulates that the record date is used to determine the ultimate beneficiary of the dividend and is therefore entitled to a settlement, reduction or refund of the dividend withholding tax. This proposal proposes to codify this provision into Dutch law. Codifying this measure into law will improve legal certainty.
This provision will only apply to listed shares. In the case of registered shares, such as in a ‘besloten vennootschap (BV)’, the ultimate beneficiary of the dividends on a specific date can be found in the company’s administration.
Set of transactions
To determine the ultimate beneficiary, the concept of a set of transactions is of importance. In any case, a person who has provided a favor in connection with received income as part of a set of transactions shall not be regarded as the ultimate beneficiary of that income.
To prevent the splitting of interests within a group and international concealment, the concept of 'set of transactions' has been further explained. Transactions entered into by an affiliated entity or person will be allocated to the taxpayer or recipient. Whether there is a set of transactions will therefore be assessed at a group level.
Burden of proof
Under current legislation, the burden of proof to demonstrate that the recipient of the dividend is not the ultimate beneficiary lies with the inspector. This proposal shifts the burden of proof to the recipient of the dividends with the aim of improving the position of the inspector. The proposed changes mean that the person or company claiming compensation must demonstrate that he or she is the ultimate beneficiary.
The proposed new burden of proof does not apply to all situations. In order not to unnecessarily burden investors with a small investment portfolio in particular, an efficiency margin has been included in the proposal. Taxpayers or dividend recipients should only demonstrate that they are the ultimate beneficiary when an amount of more than € 1,000 in dividend withholding tax is levied per financial year or calendar year.
These proposed changes will shift the burden of proof for the ultimate beneficiary from the inspector to the recipient in the event of a claim for compensation. It is therefore important that the ultimate beneficiary can be substantiated when claiming a settlement, refund or reduction of dividend withholding tax.
Would you like to know more?
Do you have any questions about this proposal and what it means for your specific situation?