The ranking on four points
| Rank | Jurisdiction | Main points |
|---|---|---|
| 1 | Netherlands | Exemption from a 5% stake for dividends and gains. About 100 treaties. Strict but predictable substance rules. Running costs for the office, the books and the filings. |
| 2 | Luxembourg | The capital of investment funds. Exemption from 10% or €1.2M. The best choice for fund structures, more expensive for entrepreneurs. |
| 3 | Ireland | 12.5% rate on trading income, plus the foreign-dividend exemption from 2025. A modernised regime. |
| 4 | Denmark / Sweden | Full exemption on business-related shares, well-organised administration, smaller treaty networks |
| 5 | Austria / Belgium | Solid regimes with higher thresholds (10% and one-year or amount tests) |
Reviewed 18 August 2026. See the full comparisons of the Netherlands with Luxembourg, Ireland and Belgium. For starting a business, there is a separate ranking. See the founder’s comparison.
Why the Netherlands still ranks first
The most important point is the threshold of 5%. Minority stakes, co-investments and stakes in companies with many shareholders all qualify. In countries with a 10% threshold, they fall outside the exemption. Capital gains are exempt as well as dividends. You find the tax treaties per country in the treaty library on this site. Companies with real operations meet the Dutch substance rules more easily. See what convincing substance means.
See the Dutch holding structure for what you save with a holding above the operating company, and what it involves each year. To keep both companies in good standing, see corporate secretarial services in the Netherlands.
The tax position of the owner
For founders, the ranking also includes their own tax position. A director-shareholder (DGA) who lives in the Netherlands has a salary benchmark of €58,000. While a new BV is still too small to pay this benchmark, you may take a lower salary for up to three years. A prior consultation with the Tax Administration gives certainty in advance. You can combine this with a loan of up to €500,000 from your own BV. The lower salary is what saves tax. At €36,000 compared with €58,000, you keep about €7,100 a year more. After a later dividend, about €2,800 of that remains. The loan gives you access to money, but the tax stays the same. Calculate it with your own figures. Apply early in the year, so the effect builds up over time.