The Netherlands has published Regulation No. 2020-0000228637of 31 December 2020 in the Official Gazette, which provides for the implementation of the substance requirement conditions in relation to the conditional withholding tax on certain interest and royalty payments with effect from 1 January 2021. The conditional withholding tax on interest and royalties is imposed at the higher corporate income tax rate of 25% and applies on payments to related parties in specified jurisdictions with a…