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New Tax Treaty Between the Netherlands and Hong Kong
On 22 March 2010 the Dutch Minister of Finance and the Secretary for Financial Services and the Treasury of the Hong Kong Special Administrative Region signed the first tax treaty between the Netherlands and Hong Kong. It has now been announced that article 10 of the treaty on dividend withholding tax has been amended.
In order to qualify for the 0% dividend withholding tax rate a number of tests need to be met, a minimum shareholding requirement of 10% being one of them. This minimum shareholding requirement did however not apply to banks, insurance companies and qualifying headquarter companies in the text of the previous version of article 10. The treaty has now been amended to include the minimum shareholding requirement also for banks, insurance companies and qualifying headquarter companies.
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