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With The Recent Unfolding Of The Dutch Government's Tax Plans For 2012, On Budget Day (Traditionally The Third Tuesday In September), It Has Become Clear That The Netherlands Will Continue To Strive At Protection Of Its Dividend Withholding Tax.

In several previous issues of WCR we have described how hybrid legal entities could be used to reduce the worldwide corporate income tax burden of a multinational group, as a matter of legal principle.

The Netherlands is under heavy attack, lately, because of its undisputed number one status in the world as treaty shopping jurisdiction.

The Netherlands has always been one of the major locations which multinational enterprises have used to reduce the tax burden on their worldwide profits.

On September 20, 2011 the Dutch government announced a number of changes to its tax laws as part of the ‘’Budget 2012’’ proposals.

In WCR December 2009 we have shown how a Dutch "Cooperative Association" might be used in a hybrid form to a foreign tax payer’s advantage via international tax planning and in WCR March 2010 a similar article was devoted to the potentially hybrid Dutch limited liability companies NV, BV and SE.

I believe I have demonstrated how the use of hybrid entities in international tax planning has changed over time, from somewhat obscure in the past to fully accepted today, as a means to save oneself considerable tax amounts in a fully legal fashion.

One of the best guarded secrets of the Netherlands is its role in international tax planning via so-called conduit companies, which collect interest, dividends, capital gains and royalty payments for multinational enterprises worldwide.

‘Substance’ is a widely known tax concept, especially used in cross-border tax situations.