The Netherlands Ministry of Finance by way of Decree of 6 December 2005, No. CPP 2005/2215M, has provided clarification on the exemption procedure with regard to dividend withholding tax under the Netherlands-Switzerland Tax treat of 12 November 1951 and the European community-Switzerland Savings Directive agreement of 26 October 2004. Tax treaty Currently, the Netherlands grants an exemption (via a refund procedure) from withholding tax if the recipient is a Swiss company that owns at least 25% of the capital in the Netherlands company which pays the dividend (Art. 9(2)(a)(i) of the treaty). Switzerland, as from 1 January 2005, grants a...