The Netherlands: Tax Plan 2024 officially approved – impact on dividend stripping rules


Clearstream Banking1 informs clients that the Tax Plan 2024 has been approved by the Dutch Senate on 19 December 2023 and published in the Dutch Official Gazette (“Staatscourant”) on 27 December 2023.


1 January 2024

the provisions tightening the dividend-stripping rules apply.


The approval of the Tax Plan 2024 strengthens the dividend-stripping rules by codifying into Dutch law the current market practice of using the record date as the entitlement date for Dutch tax purposes.

The burden of proof is also shifted from the Dutch tax authorities (DTA) to the claimant for total reclaimable amounts equal to or above EUR 1,000 for a calendar year and for the same beneficial owner. For amounts below EUR 1,000, the burden of proof remains with the DTA.

Impact on clients

Clearstream Banking expects the DTA to request additional supporting documentations on reclaims filed on behalf of its clients to prove their entitlement. Clients must be ready to receive such requests and to answer within the deadlines imposed by the DTA at the time of the request.

Further information

For further information, please contact the Clearstream Banking Tax Help Desk, Clearstream Banking Client Services or your Relationship Officer.

1. Clearstream Banking refers collectively to Clearstream Banking S.A., registered office at 42, avenue John F. Kennedy, L-1855 Luxembourg, and registered with the Luxembourg Trade and Companies Register under number B-9248, and Clearstream Banking AG, registered office at 61, Mergenthalerallee, 65760 Eschborn, Germany and registered in Register B of the Amtsgericht Frankfurt am Main, Germany under number HRB 7500.