années 2010–2026
Luxembourg–Jersey tax structure substantially reducing dividend withholding tax
An NRC investigation reported by NOS described a channel for Heineken dividends through a Luxembourg company and then Jersey, allowing Charlene de Carvalho-Heineken to incur approximately 2.5% rather than 15% Dutch withholding tax, with estimated lost tax revenue of around 30 million euros a year. Following an anti-abuse measure, another capital repayment technique was used, according to the investigation.
- State of the evidence
- Journalistic investigation, estimated amounts and legislative change documented; criminal fraud not established
- Legal status — source text
- No criminal conviction identified; structure described as tax avoidance and targeted by an anti-abuse measure
- Attribution
- Direct responsibility as beneficiary and shareholder
Sources · 2
- [1]
- [2]
Last verified: 1 September 2026