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Netherland BV

Bluepearl

New member
Good afternoon,

could somebody explain me taxation benefits of BV company in Holland? If services from company were made outside the country, like in Italy or Spain for example, profit taxes are zero, right?
How about subsidary registred in BVI where taxes are zero, can dividends be transfered in Holland and still no taxes?

Thank you in advance!
 

JustAnotherNomad

Entrepreneur
I don’t know to be honest, but I very strongly doubt that there is no CIT if the work is carried out outside the Netherlands, unless there is a permanent establishment, which is taxed in Italy/Spain. So the whole point with the Netherlands not taxing such profits would be to avoid double taxation.
With a BVI subsidiary, you can bet that it will be covered by Dutch CFC rules.
But I don’t know anything about the Netherlands, that’s just my general hunch. Anything else would be a crazy loophole.
 

neweraoffshore

IT Nerd Offshore Guy
Mentor Group Gold
That's the the tax scheme you want to build:

However this will cost you a lot of maintenance and you need the substances to make this work, too. If you do a correct invoicing and have the necessary substances then this will work. Maintaining this system is mostly only possible for international enterprises.
 

Bluepearl

New member
Well, as far as I am informed by different articles there are many benefits in Holland/

“The Netherlands offers significant taxation discounts on Intellectual property (patents, copyrights, software, etc.) related businesses. In 2010, the Dutch government had decreased the amount of intellectual property related taxes, from 10% to 5%”

There are different articles about taxation when services are made outside NL ( like Delaware for example) thats why I tried to get some useful info here.
 

Martin Everson

Offshore Retiree
Mentor Group Gold
Elite Member
You need to firstly look at the updated Dutch Substance Requirements for a company (introduced in 2018) and also demonstrate to Dutch taxman a structure is not abusive even after substance requirements are met.

Basically if you can afford to meet the minimum 100k a year in labour costs you must show also then please just setup in a tax free country and be done with it.
 

Bluepearl

New member
Well, this is why I am doing a research
Its written that non residents, owners of BV with bussines done outside NL are tax free.
I would obviously need to ask official Dutch tax advisors
 

Martin Everson

Offshore Retiree
Mentor Group Gold
Elite Member
Its written that non residents, owners of BV with bussines done outside NL are tax free.
Well if the company is not considered tax resident in Netherlands then you don't pay tax there. However you pay it where the company is considered resident (via control and operations) i.e your home country 99.9% of time...lol. Also under EU DAC6 the Netherlands will share your cross border company affairs with your home country taxman automatically....lol.

DAC6: The EU Directive on cross-border tax arrangements

I would obviously need to ask official Dutch tax advisors
Please do so. But trust me if your not resident there or your not a Fortune 500 company with the money to establish a real presence in Netherlands don't waste your time.

P.S Like I said there is no benefit but keep the research going.
 

ih8socialism

Active Member
Well if the company is not considered tax resident in Netherlands then you don't pay tax there. However you pay it where the company is considered resident (via control and operations) i.e your home country 99.9% of time...lol. Also under EU DAC6 the Netherlands will share your cross border company affairs with your home country taxman automatically....lol.

DAC6: The EU Directive on cross-border tax arrangements



Please do so. But trust me if your not resident there or your not a Fortune 500 company with the money to establish a real presence in Netherlands don't waste your time.

P.S Like I said there is no benefit but keep the research going.
Interesting subject, I'm part of an startup in the logistics sector, located in Germany, however Rotterdam is also very interesting for us due the big port. Building a real presence is not an isseu since we would require office + warehouse in Rotterdam, expansion for NL is planned for next year. However, having an HQ in a 0 Tax country is an better and cheaper option lol
 
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