Dutch list of low tax jurisdictions 2026: Barbados removed
10/01/26
The Netherlands has removed Barbados from the 2026 Regulation on low-tax states and non-cooperative jurisdictions for tax purposes. This list consists of designated low-tax jurisdictions for the application of the Dutch Controlled Foreign Corporation (CFC) legislation, for the conditional withholding tax on interest and royalty payments and, as of 1 January 2024, for the conditional withholding tax on dividend payments.
What does this mean for your organisation?
When your Dutch company pays interest, royalties, or dividends to an affiliated entity in a designated low-tax jurisdiction, it may be subject to a conditional withholding tax on these payments. Low-tax jurisdictions, in this context, are jurisdictions with a statutory profit tax rate of 9% or less, as well as countries included on the EU list of non-cooperative jurisdictions. The rate of the conditional withholding tax is equal to the highest corporate tax rate, which is 25.8% in 2026.
In addition, if your company has a participation in a Controlled Foreign Company (CFC) located in a designated low-tax jurisdiction, the Dutch CFC measure may apply. The measure ensures that “benefits from a controlled entity” are included in the taxable base of the Dutch company. As a result, your company may effectively be taxed on certain passive income generated through the CFC.
Designated low-tax jurisdictions: list applicable for 2026
The Dutch list of low-tax jurisdictions was revised at the end of December 2025. The list reflects the state of affairs as of 1 October 2025 and applies to the year 2026. The Dutch list includes jurisdictions with no profit tax or a profit tax rate of less than 9%, as well as jurisdictions included in the EU list of non-cooperative jurisdictions published in October 2025.
Compared to the 2025 list, the 2026 list no longer includes Barbados.
Opposite is an overview of the countries classified as low-tax jurisdictions for the year 2026:
| Dutch list of states without a profit tax or with a profit tax at a rate of less than 9% | EU-list of non-cooperative jurisdictions |
Anguilla Bahamas Bahrein Bermuda British Virgin Islands Cayman Islands Guernsey Isle of Man Jersey Turkmenistan Turks- and Caicos Islands Vanuatu |
United States Virgin Islands American Samoa Anguilla Fiji Guam Palau Panama Russian Federation Samoa Trinidad and Tobago Vanuatu |
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