Executive summary On 25 March 2021, the Dutch Government published a legislative proposal introducing a withholding tax on dividend payments to low-taxed jurisdictions, effective as of 1 January 2024. The withholding tax will also apply in the case of abusive situations and is an extension to the already enacted withholding tax on interest and royalty payments to low-taxed jurisdictions or abusive situations. The withholding tax rate is equal to the headline corporate income tax rate, which is currently 25%. This withholding tax will exist together with the ”normal” dividend withholding tax of 15%, although an anti-cumulation rule will apply, effectively...