Holland suggested a way to pull dividends out of a Dutch holding companiy without paying withholding taxes. The suggestion is in a decree the Dutch state secretary of finance issued in early July. It relies on Dutch tax law rather than tax treaties. It works as follows: The key is that the foreign parent of a Dutch holding company must cause itself to have a “permanent establishment” in Holland to which shares in the Dutch holding company can be attributed. There is no withholding tax on dividends paid by a Dutch holding company to the permanent establishment, or “PE,” of a foreign parent. The foreign parent must have a genuine business in Holland. This gives it a PE. The activities of its Dutch holding companies should be directly related to the PE so that they can be attributed to it. This could be done, for example, by having the foreign parent place a small staff in Holland to manage its investments or project development activity in Europe. The staff would have to have independent decision-making authority. The Dutch tax authorities will confirm by ruling that the technique works.