The Dutch Tax Authority has released its official 2025 list of nations classified as developing countries under tax treaty regulations, maintaining alignment with international development assistance criteria while applying stricter conditions for upper-middle-income economies.
The Dutch Tax Authority has published its annual list of countries designated as developing nations under Article 6 of the 2001 Double Taxation Prevention Decree (Bvdb 2001) for 2025.
Since 1 January 2017, the Netherlands has applied specific criteria to determine which countries qualify as developing nations for tax purposes. The primary standard follows the “List of Recipients of Official Development Assistance” published by the Development Assistance Committee of the Organisation for Economic Co-operation and Development.
However, upper-middle-income countries face additional requirements. These nations must also be designated under decisions made by the Minister for Foreign Trade and Development Cooperation pursuant to Article 3 of the Framework Act on Subsidies from the Ministry of Foreign Affairs.
This designation specifically relates to financing activities for small and medium-sized enterprises, making development-relevant investments. Additionally, they must have already been classified as developing countries as of 31 December 2016.
For 2025, the following territories qualify as developing countries under the 2001 Double Taxation Prevention Decree:
Afghanistan, Angola, Belize, Benin, Bhutan, Bolivia, Burkina Faso, Burundi, Cambodia, Central African Republic, Colombia, Comoros, Republic of Congo, Democratic Republic of Congo, Djibouti, El Salvador, Eritrea, Eswatini, Gambia, Guatemala, Guinea, Guinea-Bissau, Haiti, Honduras, Iraq, Iran, Ivory Coast, Yemen, Cape Verde, Cameroon, Kenya, Kiribati, Laos, Lesotho, Lebanon, Liberia, Madagascar, Malawi, Mali, Mauritania, Micronesia, Mongolia, Mozambique, Myanmar, Nepal, Nicaragua, Niger, North Korea, East Timor, Palestinian Authority-administered territories, Papua New Guinea, Peru, Rwanda, Solomon Islands, Samoa, Sao Tome and Principe, Senegal, Sierra Leone, Sudan, Somalia, Syria, Tajikistan, Tanzania, Togo, Tokelau, Chad, Tuvalu, Vanuatu, and South Sudan.
