State Secretary provides overview of tax treaty developments in the first half of 2012
Overview of treaty developments
The Ministry of Finance recently published an overview of all developments relating to tax treaties in the first half of 2012. An update was necessary since several new double tax treaties and tax information exchange treaties had been concluded and existing treaties had been amended.
Double tax treaties
In a previous newsletter we already discussed the new double tax treaty which the Netherlands concluded with Germany on 12 April 2012. This treaty is expected to take effect on 1 January 2014. Moreover, an amendment protocol was signed with India on 10 May 2012 for expanding the information exchange provisions in the existing double tax treaty to all types of tax. The effective date of the amendment protocol is yet unknown.
An amendment protocol was already concluded with Belgium in 2009. The protocol particularly addresses the exchange of information, which should effectively lead to non-application of the Belgian banking secrecy. This protocol has been ratified by the Netherlands, but has not yet become effective.
On 10 August 2012, the Netherlands also concluded a double tax treaty with Ethiopia.
Tax information exchange agreements
Three new tax information exchange agreements became effective in the past six months: i.e., with Dominica (1 March 2012), Liberia (1 June 2012) and Samoa (2 March 2012).
The Netherlands has concluded tax information exchange agreements with several countries which have not yet become effective. This concerns agreements with the British Virgin Islands, Costa Rica, Grenada and the Seychelles.
Source: Circular by the State Secretary for Finance of 6 August 2012, “Verdragenoverzicht op het gebied van directe belastingen per 1 juli 2012”, and Newsletter of 13 August 2012