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He new cabinet is more stringent for the Dutch trust sector. Stricter rules are being introduced and the powers of supervisor De Nederlandsche Bank (DNB) are extended, according to statements in the coalition agreement.

The ‘information position and detection capacity’ of the Tax authorities are also ‘strengthened’. There will also be ‘more transparency’. ‘To this end, a business case is worked out‘, according to the four forming parties VVD, CDA, D66 and Christen Unie.

Cabinet sensitive to international criticism

The new cabinet is sensitive to the international criticism received by The Netherlands in recent years due to billions flowing through Dutch letterbox companies, with the main purpose of evading tax.

‘We want to put an end to the situation that firms only establish themselves on paper in The Netherlands to be able to recirculate tax-free millions‘, it says in the coalition agreement. ‘On an international level, we are committed to tackling tax havens.‘

Withholding tax on interest and royalties

‘I do not think that The Netherlands is a tax haven, but that we have to act harder against Letterbox-Ltd’s‘, said Prime Minister Mark Rutte during the presentation of the coalition agreement. Therefore, a withholding tax is introduced on interest and royalties on outbound cash flows to tax havens.

‘I don’t think that The Netherlands is a tax haven, but that we have to act harder against Letterbox-Ltd’s‘
Prime Minister Mark Rutte

This means that no tax treaties need to be adjusted. With most tax havens (officially ‘low-tax countries’), The Netherlands does not have a tax treaty.

The new cabinet estimates the revenues of the new levy to zero. The forming parties expect that Letterbox-Ltd’s that channel money to tax havens will cease to exist due to the measure, confirms Wouter Koolmees who was on the negotiating table on behalf of D66.

Ambiguity about new rules

It is still unclear what the new rules for the trust sector and the new powers of DNB and the tax administration will look like. DNB and the Ministry of Finance do not want to respond to the coalition agreement and refer to the new cabinet.

Dijsselbloem, the outgoing Minister of Finance, said this summer that there was a law in the making that also would give DNB the power to close trust offices. The trust sector itself could not react directly through the trade association Holland Quaestor. It is striking that trust office and business services provider TMF last week announced to move its head office to London and to pursue a stock market listing there.