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Netherlands: License fees for images, trade names, and logos treated as royalties under Australia income tax treaty

The guidance addresses the characterization of certain licensing payments under the Netherlands-Australia income tax treaty.

august 6, 2026

The Dutch Tax Administration on July 7, 2026, published guidance clarifying that license fees paid for the use of images, trade names, and logos qualify as royalties under Article 12(3) of the Netherlands-Australia income tax treaty.

The clarification confirms that payments for the right to use underlying copyrights and trademarks are treated as royalties and are eligible for relief through the treaty's foreign tax credit provisions.


For more information, contact a KPMG tax professional in the Netherlands:

Paul Te Boekhorst | teboekhorst.paul@kpmg.com

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