Executive summaryThe Dutch Government enacted, on 27 December 2019, a withholding tax on interest payments and royalties to low tax jurisdictions and in abusive situations, effective as of 1 January 2021. This new withholding tax will have a rate of 21.7%. If a treaty jurisdiction would fall under the low-tax jurisdiction definition, there is a three-year grandfathering period applicable for such jurisdiction.1Also on 27 December, the Dutch Government enacted additional substance requirements for Dutch intra-group financing and/or licensing companies related to the exchange of information, again effective as of 1 January 2021. If the additional substance requirements are not met, additional...