Benin sends Netherlands tax treaty to parliament

A ratification step, not an operative treaty

The Council's official report records the transmission decree and identifies the convention as the treaty signed on 21 May 2026. The Netherlands published the full text in Treaty Series 2026, No. 66. Its treaty database records the conclusion date but leaves provisional application and entry into force blank. Businesses should therefore continue to apply the existing domestic-law position and any other applicable instrument rather than claim benefits under this convention.^[1][2][3]

Proposed withholding ceilings

If the convention enters into force, Article 10 would cap source-country tax on dividends at 5% where the beneficial owner is a company holding directly at least 10% of the payer's capital throughout a 365-day period that includes the payment date. The ceiling would be 15% in other cases. Articles 11 and 12 would generally cap source-country tax on interest and royalties at 10%, subject to the treaty's conditions and specified interest exemptions.^[2]

Anti-abuse and cooperation provisions

The convention contains entitlement-to-benefits safeguards, exchange-of-information and assistance-in-collection provisions. Its protocol also states that the convention does not prevent either state from applying domestic legislation that implements the OECD GloBE rules and associated commentary or administrative guidance. Those provisions do not themselves establish that a group qualifies for reduced withholding or another treaty benefit.^[2]

Entry into force remains conditional

Article 29 provides that the convention would enter into force on the last day of the month following receipt of the later written notification that each state's constitutional formalities have been completed. It would then apply to taxable years and periods beginning, and taxable events occurring, on or after 1 January of the following calendar year. The treaty creates no standalone filing deadline. Groups should monitor both ratification processes and verify residence, beneficial ownership, the holding period and domestic relief procedures before applying any future rate.^[2][3]