The Netherlands now has a tax treaty with almost 100 countries

State Secretary for Tax Affairs, Tax Administration and Customs, Tjebbe van Oostenbruggen (NSC), has provided both Chambers with a written update on current and planned treaty negotiations. 

In view of its open economy and relatively small home market, the Netherlands benefits enormously from having an extensive network of tax treaties. At the moment the Netherlands has an active tax treaty with 98 countries. In his letters to both Houses of Parliament, State Secretary Van Oostenbruggen furnished a list of the negotiations and ratification procedures in 2024, together with a preview of negotiations in 2025.

Review 2024

Several tax treaties were adopted in 2024 which have since entered into force, on 1 January 2025. These included the tax arrangement with Curaçao, an amendment to the tax treaty with Moldova and tax treaties with Andorra and Kyrgyzstan. Further to this, agreement was reached concerning the amendment of the tax arrangement with Sint Maarten, the tax treaty with Bangladesh has been signed by both countries and the Cabinet has given its approval for a change in the tax treaty with Germany. 

Preview 2025

It is expected that the treaties with Bangladesh, Belgium and Germany and the tax arrangement with Sint Maarten will be submitted to the House for adoption in 2025. 

Negotiations are also in progress with various countries, including Belgium (specifically over a working from home arrangement), Sweden, Portugal, Romania and Suriname.

The separate paragraph devoted to neighbouring countries in the State Secretary’s letters is notable. 

The Cabinet approved an amendment to the treaty with Germany in 2024. This amendment agreed on the tax treatment of cross-border workers working from home, making occasional home working easier. A suitable moment for signature is still being sought. The Netherlands would like to make more extensive agreements, also to more easily facilitate working from home on a regular basis, and is in contact with Germany about this.  

A new tax treaty was signed with Belgium in 2023. Both countries are working on a joint set of explanatory notes to this treaty and are currently finalising that document. They are also in discussion about the inclusion of a possible home working arrangement in the tax treaty to facilitate (occasional) working from home by cross border workers. No specific agreements on this have yet been made, partly because the Belgian government was outdoing for some time (a caretaker government). 

The amendments to the treaties with Portugal, Romania and Sweden envisaged by the Netherlands mainly concern agreements surrounding the right to levy tax on pension benefits.