What is the BOR?
The BOR is a significant tax relief for transferring a business to the next generation. Absent BOR, gift and inheritance tax (schenk- en erfbelasting) on business assets would apply at up to 40%. With BOR, the going concern value of the business is exempt from tax (100% up to €1,534,500, 75% above that in 2026).
Conditions for BOR
- The business must be an active enterprise (rather than a passive investment holding)
- The donor must have owned the business for at least 3 years before gifting (5 years on inheritance)
- The recipient must continue the business for at least 3 years after transfer
- The BOR applies to BV (besloten vennootschap, the Dutch private limited company) shares while passive real estate portfolios stay outside
Tax-free amounts 2026
| Business value | BOR exemption |
|---|---|
| Up to €1,534,500 going concern value | 100% exempt |
| Above €1,534,500 | 75% exempt |
Early planning is key
The 5-year ownership requirement for the donor means BOR planning should start well before any intended transfer. Combined with gradual share gifting and the annual gift tax exemption (around €6,700 per child), a structured multi-year plan can transfer significant business value virtually tax-free.
Where this leads
This question continues in Transferring Your Business to Your Child, Selling a Business via a BV and Selling Your Business.