Dutch withholding tax (WHT) reclaims now require an RSIN for most beneficial owners and legal entities, and new claimants must obtain this identification number before filing.
What changed
The Dutch Tax Authorities have updated the electronic reclaim portal so that an RSIN (Rechtspersonen en Samenwerkingsverbanden Informatienummer) of the beneficial owner / legal entity is now a mandatory field for Dutch WHT reclaims. The RSIN is a unique tax ID that already appears in past Dutch tax decisions; for example, in a reference like 123456789TDI20250006, the first 9 digits are the RSIN.
Who is affected
- Any new refund claimant (no previous Dutch WHT reclaims) must first register and obtain an RSIN before submitting a reclaim.
- Entities that have filed before should retrieve their RSIN from prior decision letters and use it in all new filings.
- Currently, reclaims filed on behalf of (non‑transparent) funds can still be submitted without an RSIN, but the Dutch Tax Authorities have indicated this requirement will be extended to such fund claims; the timing is not yet announced, and fund transparency is assessed under Dutch law.
Timing and practical steps
- The Dutch Tax Authorities indicate an RSIN application typically takes about 8 weeks, so this extra step can delay first‑time WHT reclaims.
- New claimants should complete the foreign company registration form and send the signed original by regular mail to Belastingdienst/Klantgegevens, Postbus 2892, 6401 DJ Heerlen, The Netherlands, as soon as they know they will need to file.
- All claimants must also respect the three‑year statutory limitation period for Dutch WHT reclaims.
Broader opportunity for funds
In 2025, the European Commission issued a reasoned opinion (INFR(2024)4017) stating that the Dutch tax levy reduction scheme (afdrachtvermindering) breaches the free movement of capital under Article 63 TFEU and Article 40 EEA. This significantly strengthens the position of non‑resident investment funds seeking refunds of Dutch dividend withholding tax, making well‑prepared reclaim strategies even more valuable.
