Karel’s Legal Blog

The treaty deals with the Netherlands Antilles

There is a treaty between the Kingdom of the Netherlands in respect of the Netherlands Antilles and the Kingdom of Norway for the avoidance of double taxation and prevention of fiscal evasion with respect to taxes on income and on capital. The treaty became effective 1 January 1991.

The treaty is applicable to persons (including companies) who are resident of one or both of the contracting states. Under the treaty withholding tax on dividends in Norway is reduced from 25% to 15% if paid to a Netherlands Antilles company which is the beneficial owner and holds a participation in the Norwegian company of less than 25%. The withholding tax on dividends in Norway is reduced from 25% to 5% if the Netherlands Antilles company holds more than 25% of the shares of the Norwegian company. The treaty is based on the OECD Model Treaty and therefore contains a limitation of benefits provision along the lines of the OECD Model.

On the basis of this treaty the competent authorities shall exchange such information as is necessary for carrying out the provisions of the treaty and of the domestic laws of the contracting states concerning taxes.

Karel Frielink
Attorney (lawyer) / Partner

Filed under: legal by Karel.Frielink