The Dutch tax authorities (DTA) have updated the electronic filing system for Dutch withholding tax (WHT) reclaims to require the RSIN (Rechtspersonen en Samenwerkingsverbanden Informatienummer) of the beneficial owner or legal entity. The RSIN is a unique tax identification number; it appears in prior DTA decisions (for example, a decision reference of 123456789TDI20250006 indicates RSIN 123456789). For entities that have previously filed WHT reclaims, the RSIN will be present on past decisions. However, entities that are new to filing WHT reclaims must now obtain an RSIN before submitting a WHT reclaim, adding an additional administrative step and potential delay.
Recent development
Key impacts
New refund claimants must register for an RSIN before submitting a Dutch WHT reclaim. The DTA indicates a RSIN application typically takes around 8 weeks.
Existing entities with past DTA decisions should locate the RSIN in those decisions to include it in filings.
Currently, filings submitted on behalf of (non-transparent) funds do not require an RSIN, but the DTA has indicated this requirement will be extended to such fund claims in the future (timing not yet provided). The transparency of the non-resident funds is determined according to the Dutch law.
Recommended next steps
If the entity has previously filed WHT reclaims, locate the RSIN on prior DTA decision letters and use it in new filings.
If the entity is new to DTA filings, apply here for an RSIN as soon as possible. The signed form must be sent by regular mail to:
Belastingdienst/Klantgegevens
Postbus 2892
6401 DJ Heerlen
The Netherlands
KPMG comment
KPMG recommends proactively registering any entity that may need to file refunds and we can assist with preparing and submitting RSIN registration forms, act as authorized representatives, and manage DTA correspondence to reduce the risk of missed deadlines.
We are also available to prepare and file WHT reclaims on your behalf and advise on documentation and timing to optimize refund outcomes. We remind you that the statutory limitation period to file the reclaims is three years.
Also worth noting that in 2025 the Commission issued a reasoned opinion to the Netherlands (INFR(2024)4017), concluding that the Dutch tax levy reduction scheme (afdrachtvermindering) breaches the free movement of capital as enshrined in Article 63 of the Treaty on the Functioning of the European Union and Article 40 of the Agreement on the European Economic Area. This development significantly improves the chances of success for non-resident investment funds to obtain refunds of Dutch dividend withholding tax.
Our team of tax specialists and project managers can assist you with filing these WHT reclaims.
