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Netherlands
"Netherlands holding structure gave us treaty access and credibility with investors globally. The participation exemption saved millions on exit."
Company Formation & Holding Structures
- BV (private limited company) minimum capital €0.01, standard structure for holding companies
- 25.8% corporate tax rate (19% on first €200,000 profits, 25.8% above)
- Participation exemption: 0% tax on dividends and capital gains from qualifying subsidiaries (>5% shareholding, subject to asset test)
- Innovation Box regime: 9% effective tax rate on qualifying IP income (R&D required)
- Extensive treaty network (100+ DTAs) with favorable withholding tax rates
- Popular for IP holding, royalty structures, international holding companies and group financing
Substance Requirements
- Real economic substance required: local directors, employees, office space
- Board meetings, decisions and operations must occur in Netherlands
- Tax authorities actively scrutinize substance (anti-avoidance rules strengthened)
- Transfer pricing documentation required for intra-group transactions
- Substance requirements manageable but cannot be pure shell company
- Combine with professional management services, accounting and legal support
Tax Treaty Benefits
- Withholding tax reduction or elimination on dividends, interest, royalties through treaties
- Gateway jurisdiction for routing dividends, IP income to low-tax destinations
- EU Parent-Subsidiary Directive: 0% withholding on dividends to/from EU parents
- Interest and Royalty Directive: 0% withholding on qualifying payments within EU
- Anti-abuse rules and substance tests apply (cannot be pure conduit)
- Advance Tax Rulings (ATRs) available for certainty on complex structures
Banking & Business Environment
- World-class banking infrastructure (ING, ABN AMRO, Rabobank plus all major international banks)
- English widely spoken; international business culture
- Highly skilled workforce, strong in tech, finance, logistics
- Gateway to EU single market
- High quality of life, education, healthcare
- High operating costs (salaries, rent, taxes) compared to Eastern/Southern Europe
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Important Notice: Aventarys Group connects clients with licensed third-party professionals. We do not provide legal, tax, accounting, or financial advice. All services are delivered by independent licensed providers. Clients should consult their own legal and tax advisors before making any decisions.
