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The Netherlands considers the re-introduction of a withholding tax for foreign artistes and sportspersons

By Dr Rijkele Betten

The Netherlands has recently amended its tax treaty policy regarding the (non) inclusion of Article 17 Artistes and Sportspersons in its tax treaties.

As from 2011, the tax treaty policy has been to try and exclude Article 17 from tax treaties so that income from artistes and sportspersons would only be taxed in the residence state.

Already from 2007, The Netherlands has abolished the then existing Netherlands withholding tax on such remunerations.

Recently, the Under Minister of Finance has indicated that, although The Netherlands’ position in tax treaty negotiations remains flexible, with the goal of avoiding or limiting international double taxation, he finds it useful to investigate whether to re-introduce a Netherlands withholding tax on the remuneration of foreign artistes and sportspersons. As a main argument, he suggests that such own withholding tax would improve the position of The Netherlands to negotiate beneficial tax treaties.

The re-introduction of such a withholding tax is thus by no means certain, and, on top of that, we will be having a general election in March 2021, so that any concrete action will be in the hands of the forthcoming Government.

Forming a coalition Government in The Netherlands is often a time-consuming process, so the timing of any concrete action in this matter, if any, is uncertain.

Dr Rijkele Betten may be contacted by e-mail at ‘This email address is being protected from spambots. You need JavaScript enabled to view it.

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Global Sports Law and Taxation Reports feature: articles; comparative surveys; commentaries on topical sports legal and tax issues and documentation.

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The Editors

The editors of  the Journal Sports Law & Taxation are Professor Ian Blackshaw and Dr Rijkele Betten, with specialist contributions from the world's leading practitioners and academics in the sports law and taxation fields.

The Editors

Managing editor
Dr. Rijkele Betten

Consulting editor
Prof. Dr. Ian S. Blackshaw

Editorial board

Prof. Guglielmo Maisto
Maisto e Associati, Milano

Dr. Dick Molenaar
All Arts Tax Advisors, Rotterdam


Mr. Kevin Offer
Hardwick & Morris LLP, London

Mr. Mario Tenore
Maisto e Associati, Milano


Nolot BV
St. Jorisstraat 11
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