4 minutes read
This article explores the complexities of dividend WHT for U.S. (MNEs investing in Switzerland and the Netherlands. It highlights the distinct tax treatments in these jurisdictions, focusing on the specific challenges and opportunities for U.S. MNEs. From a Swiss tax perspective, the article addresses the old reserves practice and its implications, emphasizing the importance of assessing refund positions before acquiring participations. It also considers the potential impact of a new tax treaty between the U.S. and Switzerland. From a Dutch tax perspective, the article discusses the conditions for the Dutch domestic dividend WHT exemption and its interaction with the U.S.-Netherlands tax treaty, as well as the new Dutch tax entity classification rules effective 1 January 2025. By examining domestic WHT regulations and bilateral tax treaties, the article provides an overview of key considerations for U.S. MNEs to navigate the current and future WHT landscapes in these countries.
Download the full article below. For further information, feel free to contact our tax experts. This article was originally published in the International Tax Journal (Wolters Kluwer: Tax Law).
