Double Taxation Relief Manual: Guidance by country: Netherlands: Dividends
Dividends are taxable in the source state at a rate of 15% if they are payable by a property investment vehicle, such as a United Kingdom Real Estate Investment Trust.
Dividends are exempt from tax in the source state where the beneficial owner of the dividends is a company which controls at least 10 per cent of the company paying the dividend (unless this company is a property investment vehicle) or is a pension scheme or charity.
In respect of all other recipients, the source state taxation is at a rate of 10 per cent.
The reduced rates provided by the treaty are not given if the dividend is effectively connected (see INTM153110 fifth sub-paragraph) with a permanent establishment which the United Kingdom resident recipient has in the Netherlands.