De Nederlandsche Bank has published new statistics showing that income from foreign direct investment and royalties channelled through the Netherlands to low-tax jurisdictions continued to decline in 2024, with the remaining flows now mainly taking the form of dividend distributions rather than royalties. The data highlight the Netherlands’ large role in multinational corporate structures, with inward and outward direct investment positions at year-end 2024 of EUR 4,946 billion and EUR 5,759 billion, equivalent to 436% and 508% of GDP. DNB reports that direct investment and royalty income routed from the Netherlands to low-tax jurisdictions fell from EUR 37 billion in 2019 to EUR 5 billion in 2020 and has remained structurally lower since, at just over EUR 6 billion in 2024. Royalty-related profits averaged EUR 24 billion a year in 2015–2019 but dropped to under EUR 1 billion in 2024, a decline DNB links to anti-avoidance measures including Dutch withholding taxes on interest and royalties (2021) and dividends (2024), alongside the global 15% minimum corporate tax rate that took effect in 2024.
De Nederlandsche Bank 2025-12-15
De Nederlandsche Bank data show profits routed via the Netherlands to low-tax jurisdictions fell further in 2024
De Nederlandsche Bank reports a continued decline in income from foreign direct investment and royalties routed through the Netherlands to low-tax jurisdictions in 2024, with flows now primarily as dividend distributions. The Netherlands' inward and outward direct investment positions at year-end 2024 were EUR 4,946 billion and EUR 5,759 billion, respectively. This decline is attributed to anti-avoidance measures, including Dutch withholding taxes and the global 15% minimum corporate tax rate effective in 2024.