Netherlands-Russia DTT suspended since August 2023. 15% WHT on dividends, 20% on interest. Dutch holding structures affected and what still works in 2026.
Netherlands and Russia: a historically important relationship
What Dutch companies now pay: the full impact
Dutch participation exemption: does it still work?
Dutch holding structures: what still works, what does not
Operating in Russia under Dutch ownership in 2026
Exit from Russia: specific Dutch considerations
The Netherlands has long been one of the most significant foreign investors in Russia — Dutch-registered holding companies were widely used by Russian and international groups to hold Russian assets, benefiting from the 1996 Russia-Netherlands DTT and the Dutch participation exemption regime.
Russia's suspension of Decree No. 585 in August 2023 struck particularly hard at Dutch-Russia structures, given the volume of intercompany flows and the historically favourable rates: 5% on dividends for substantial holdings (≥25%), 0% on interest, 0% on royalties.
As of mid-2026, an estimated 20–25 Dutch-headquartered operating companies maintain active Russian subsidiaries. The picture is more complex for Dutch holding companies that were set up to hold Russian assets for non-Dutch ultimate shareholders — many of these have been restructured or are in the process of being unwound.
For Dutch holding companies that funded Russian subsidiaries with intercompany loans — a common structure that generated tax-efficient returns before 2023 — the shift from 0% to 20% WHT on interest is often the most significant financial impact. A Russian subsidiary with a €10M intercompany loan at 8% interest would pay €800,000 in interest annually, subject to €160,000 in WHT that previously cost nothing.
The Dutch participation exemption (deelnemingsvrijstelling, Article 13 CITA) exempts qualifying dividends and capital gains from Dutch corporate tax when the Dutch company holds at least 5% of the share capital of the subsidiary.
The participation exemption is a domestic Dutch rule — it does not depend on the DTT with Russia. For Dutch companies that qualify, dividends received from Russian subsidiaries are still exempt from Dutch corporate tax.
The consequence, however, is that the 15% Russian WHT becomes a permanent, irrecoverable cost. There is no Dutch tax liability against which to credit the Russian WHT. The Dutch tax authority does not provide a refund of foreign WHT where the income itself is exempt under the participation exemption.
Dutch companies can claim a deemed credit (verrekenbaar geacht) for foreign WHT in certain circumstances under Article 23d CITA — but only up to the amount of Dutch tax that would otherwise have been due on the income. Where the income is exempt, the deemed credit is zero.
One available mechanism: the Netherlands has a tax credit for foreign taxes in the "switch-over" regime (Article 13aa CITA), which applies when the foreign entity is subject to tax at a rate less than 9% (the Dutch low-tax threshold). Russia's standard CIT rate is 25%, well above this threshold, so switch-over does not apply to standard Russian subsidiaries.
Many Dutch-Russia structures were built around three features: (1) the 5% dividend WHT, (2) 0% interest WHT on downstream loans, and (3) the Dutch participation exemption. With features (1) and (2) eliminated by the suspension, the economic rationale for maintaining Dutch intermediate holding companies has changed significantly.
Dutch holding company holding Russian subsidiary, charging management fees or royalties from Russia → 20% WHT on all payments
Dutch SPV lending to Russian operating company → 20% WHT on interest, eroding the lending margin
Dutch conduit for dividend flow to non-EU ultimate shareholder → 15% Russian WHT plus potential Dutch dividend WHT
Dutch operating company with genuine Russian subsidiary (no significant intercompany payments) → dividends at 15% WHT, manageable if volumes are moderate
Dutch parent of Russian subsidiary where dividend extraction is not the primary goal — where Russia generates profit that is reinvested locally
Unwinding a Dutch holding structure is not straightforward. Transfer of shares in a Russian subsidiary from a Dutch company to a non-Dutch entity requires Russian Government Commission approval if the Dutch company is from an "unfriendly" country. The approval process and mandatory discount requirements apply. Dutch exit taxation may also apply when assets leave the Netherlands tax jurisdiction.
Dutch companies that continue to operate Russian subsidiaries in 2026 face a specific set of practical issues:
Reporting to Dutch shareholders and banks: Dutch-listed or bank-financed groups face the strongest pressure to address Russian exposure. ING, Rabobank, ABN AMRO and other Dutch banks have largely withdrawn from Russia-related financing and are increasingly cautious about corporate clients with significant Russian operations. Annual report disclosures of Russian assets and earnings attract scrutiny from investors and regulators.
Sanctions compliance: The Netherlands implements EU sanctions fully. Dutch company boards face personal liability risk for sanctions breaches by their Russian subsidiaries, including cases where the Russian subsidiary inadvertently receives or supplies sanctioned goods or services. Dutch companies must implement robust compliance controls at the subsidiary level, not just at the parent.
Dividend policy: Given 15% WHT, many Dutch parents have moved to a "no distribution" policy for Russian subsidiaries — accumulating profits in Russia rather than paying WHT. This has the side effect of inflating Russian subsidiary balance sheets, which may trigger mandatory audit requirements (balance sheet >RUB 400M) and increase the Government Commission approval threshold for any future exit.
Practical support for international business in Russia.