Pending legislation in the Netherlands may change how Dutch Coops are utilized in holding structures. Current legislation dictates that Dutch Coops do not have to withhold dividend withholding tax if they are making profit distributions to participants. This makes it is very appealing for multinational companies to utilize this method to structure worldwide shareholdings, because when structured correctly, it can result in tax-free dividends and distribution without Dutch withholding tax.
It seems, however, that there is legislation in the works to make it more difficult to structure this way. An impending investigation may be looking into the differences between Coop structuring and the normal NV/BV for taxation purposes. Additional insights are scheduled to be released on Sept. 20, 2016.