Incorporating a BV

Dutch Business Succession Relief (BOR) 2026

Updated: 2026 Holdwise editorial team Netherlands 2026 English

Under the Dutch business succession relief (Bedrijfsopvolgingsregeling, BOR), a family member who receives a business as a gift or inheritance pays much less tax. The first €1,543,500 of business value is fully tax-free in 2026. Above that amount, 75% relief applies. The rules have changed a great deal in recent years. At Holdwise, we keep this answer up to date and change it when the rules change.

Complete guide Incorporating a BV: Step-by-Step Guide 2026 (From Idea to KVK) →

Changes in 2025 and 2026

The full exemption rose from €1,325,253 to €1,500,000 in 2025 and was indexed to €1,543,500 in 2026. Above that amount the relief is 75%, where it was 83% before 2025. The continuation period went from 5 to 3 years. The holding period stayed 5 years for a gift and 1 year on death, and the period now continues after a restructuring. There is now also a minimum age of 21 years for the recipient of a gift. For inheritance, the recipient can be any age.

How the relief works

The business value is split into two parts. The first €1,543,500 is 100% tax-free. Of the part above that, 75% is tax-free, and the remaining 25% is taxed at the standard gift or inheritance tax rates. If a child receives a business worth €3 million, the child typically saves around €527,000 in inheritance tax with the BOR.

Conditions to qualify

The donor must have owned the business for 1 year in the case of inheritance, and for 5 years in the case of a gift. The business must be an active operating company; a passive investment company is excluded. The recipient must be at least 21 years old at the time of a gift. They must continue the business for 3 years. Selling it, liquidating it, or turning it into a passive holding is prohibited.

Investment assets and operating assets

Only operating assets qualify for the BOR. Surplus cash, passive investments and rented-out property are more and more often treated as investment assets. These assets then fall outside the relief. A BV with a lot of property or cash therefore gets much less relief from the BOR than under the old rules.

A holding structure has two Dutch companies, one above the other. Each company has its own deed of incorporation. See the Dutch holding structure for non-residents. For the shareholder register, the board decisions and the yearly filings of both companies, see corporate secretarial services in the Netherlands.

Families that keep a business, real estate and investments together in one structure use a family office. In the Netherlands, it is set up with a holding company and a foundation that issues depositary receipts (STAK). See a family office in the Netherlands for how this works.

Terms on this page

Business succession scheme (BOR): Under this scheme, gift and inheritance tax on business succession is largely exempt. The exemption is full up to the statutory threshold and partial above it. The conditions are active business assets and the continuation requirement.
Holding company: A BV that owns shares in other companies. Under the participation exemption, the holding receives dividends and sale proceeds free of corporate tax. In the holding, the capital is protected and you can let it grow.
Depositary receipt (certificaat): The proof of economic ownership a STAK issues against the shares the foundation owns. The certificate holder receives dividend and value growth. Voting rights stay with the foundation board.

All terms in the glossary →

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Part of Doing Business in the Netherlands, the complete 2026 guide.

Frequently asked questions

What is the BOR exemption in 2026? +

The first €1,543,500 of business value is fully tax-free. Above that, 75% relief applies (as in 2025; 83% until 2024). The remaining 25% is taxed at standard rates.

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

3 years, where it was 5 years before 2025. If you sell the business, liquidate it or turn it into a passive holding within 3 years, you lose part or all of the relief. Tax interest is added on top.

Does BOR apply to rented-out real estate? +

Less and less. Since 2024, rented-out properties are usually treated as investment assets and fall outside the BOR relief. A BV with a lot of property in passive rental saves much less.

Sources Belastingdienst · KVK · wetten.overheid.nl Last updated: 2026