Dutch Business Succession Relief (BOR) 2026

Updated: 2026 Netherlands 2026 English

When a Dutch business is transferred to a family member by gift or inheritance, the BOR (Bedrijfsopvolgingsregeling) provides substantial tax relief. The first €1.5 million of business value is fully tax-free in 2026; above that, 70% relief applies. The rules have changed significantly — here is the current state.

The 2025/2026 changes in one overview

Full exemption raised from €1,325,253 to €1,500,000. Above the cap: 70% relief in 2026 (was 75% in 2025, 83% before 2025). Continuation period reduced from 5 to 3 years. Holding period reduced from 5 to 3 years for gifts. Minimum age of recipient introduced: 21 years for gifts (no minimum for inheritance).

How the relief works

Business value is split: first €1,500,000 is 100% tax-free. The portion above is 70% tax-free; remaining 30% taxed at standard gift or inheritance tax rates. For a €3M business transferred to a child, BOR typically saves around €466,000 in inheritance tax.

Conditions to qualify

For the donor: holding period of 1 year for inheritance, 3 years for gifts. The business must be an active operating company (not a passive investment vehicle). For the recipient: minimum 21 years old at gift; must continue the business for 3 years; cannot sell, liquidate or convert to a passive holding.

Investment vs. operating assets

Only operating assets qualify for BOR. Excess cash, passive investments, rented-out real estate are increasingly classified as investment assets and excluded from the relief. For BVs holding substantial real estate or cash, the BOR benefit is much smaller than under previous rules.

Frequently Asked Questions

What is the BOR exemption in 2026? +

First €1,500,000 of business value is fully tax-free. Above that, 70% relief applies (down from 75% in 2025). The remaining 30% is taxed at standard rates.

How long must I continue the business after BOR transfer? +

3 years (was 5 years before 2025). If you sell, liquidate or convert to a passive holding within 3 years, the relief is partially or fully clawed back plus tax interest.

Does BOR apply to rented-out real estate? +

Increasingly limited. Since 2024, rented-out properties are typically classified as investment assets and excluded from BOR relief. For BVs with substantial real estate in passive rental, the savings are much smaller.