Based on current legislation, cooperatives are in principle not obliged to withhold dividend withholding tax. From a letter dated May 27, 2016 that was sent to the Lower House, it can be inferred that the Deputy Minister of Finance, Eric Wiebes, wants to change this by January 1, 2018 at the latest.
In his letters of November 27, 2015 and February 2, 2016 he had already announced that the different tax treatment of, on the one hand, cooperatives and, on the other hand, NVs and BVs would be investigated. The latter are in principle obliged to withhold dividend withholding tax, while a cooperative is excepted from this (except in situations of abuse), even if the cooperative is not used as originally intended, but as a holding cooperative in international structures. As far as the Cabinet is concerned, there are no grounds for this. Mr. Wiebes stated that he will present proposals for ending this different treatment on Budget Day. After the Budget Day letter, a bill will be submitted, with the intention being for it take effect on January 1, 2018.
In his latest letter Mr. Wiebes does however state that the Netherlands is, and will continue to be, an advocate of the internationally-accepted basic assumption of not levying dividend withholding tax on shareholding structures, provided there is a business chain. A precondition for him is that real cooperative businesses are not affected.