The approach to dividend stripping has been intensified since the end of 2023. The Tax Authority is taking strict action against cases of dividend stripping. However, dividend stripping is very complex and has many forms, making the approach to dividend stripping not straightforward. Therefore, the previous cabinet introduced new measures as of 2024 and has investigated whether more measures are possible in recent times. This research also looked at what the Netherlands can learn from other countries. Four possible measures have emerged from the research.

The four possible measures will be further developed in the coming period. Important aspects such as feasibility, limiting the impact on regular stock trading, effects on citizens and businesses, and compatibility with European law and tax treaties will also be taken into account. The four measures will be presented for internet consultation this autumn. After the consultation, the measures will be weighed, and the cabinet will decide whether new legislation will be proposed.

The first measure focuses on the so-called net return approach. This measure will prevent someone from receiving a refund in dividend tax while the return on the shares does not or hardly reaches that person. A so-called efficiency threshold can be used here, which can exclude many situations where the risk of dividend stripping is limited from the measure.

The second measure aims to counteract dividend stripping through pension funds. Pension funds can be used to obtain a refund in dividend tax for the actual shareholder who has no or less right to that refund. Under this measure, a pension fund will no longer have the right to an exemption or refund of dividend tax if the dividend relates to a business activity that is not related to the regular activities of the pension fund.

The third measure comes from research into neighboring countries. This research shows that Germany and Austria have a measure to combat dividend stripping that also seems adaptable in the Netherlands. In both countries, a person only has the right to a refund in dividend tax if they actually bear the economic risk of the shares over a certain period. Further research will be conducted on whether and how such a measure can be integrated into the Dutch system.

The fourth measure concerns clarifying the rules regarding group structures, making it clearer what is and is not allowed.

The four possible measures will be further developed in the coming period. Important aspects such as feasibility, limiting the impact on regular stock trading, effects on citizens and businesses, and compatibility with European law and tax treaties will also be taken into account. The four measures will be presented for internet consultation this autumn. After the consultation, the measures will be weighed, and the cabinet will decide whether new legislation will be proposed.