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Dutch clarification on credit for withholding tax and application of redistribution

17 December 2006

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Treaty Development

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Netherlands-United Kingdom

facility for dividends received from UK published On 31 October 2006, the Director-General for Fiscal Affairs (Directorate International Affairs) of the Ministry of Finance published a clarification with respect to the credit for withholding tax and the application of the redistribution facility for dividends received from the United Kingdom. Details are summarized below. (a) Background. The UK tax system grants a tax credit to residents of the United Kingdom to avoid double taxation on dividends. Art. 10(3) of the Netherlands-UK income of 7 November 1980 provides that this credit is also granted to shareholders resident in the Netherlands under certain...