On 6 December 2022, the Dutch State Secretary of Finance published a Decree regarding the application of the Dutch hybrid provisions in the Dutch Dividend Withholding Tax Act 1965 (DWHTA) and the Conditional Withholding Tax Act 2021 (CWHTA).The new Decree provides favorable guidance for scenarios involving a Dutch disregarded entity (withholding agent) making a payment of dividends, interest or royalties to another hybrid entity.Executive summaryThe hybrid entity rules included in the DWHTA and the CWHTA, as well as certain applicable tax treaties, contain provisions on how to treat payments involving hybrid entities. In practice, there is ambiguity as to the...