Route 1: silent contribution (geruisloze inbreng)
The business moves into the BV at book value; the tax claim on hidden reserves and goodwill rolls forward into the BV. Conditions: a request to the Tax Authority, contribution of the whole enterprise, and a three-year holding intention on the shares. Retroactive effect to 1 January is available when the preliminary agreement is registered before 1 October.
Route 2: taxed contribution (ruisende inbreng)
You settle now: the difference between market and book value (hidden reserves, goodwill) is taxed as discontinuation profit — softened by the discontinuation relief and the option to convert into an annuity. Attractive when the reserves are modest or when you want a clean, stepped-up opening balance in the BV.
Which route fits
| Silent | Taxed | |
|---|---|---|
| Tax now | 0 — claim rolls forward | Over reserves and goodwill |
| Opening balance BV | Book values | Market values (more depreciation) |
| Best at | Substantial hidden reserves | Modest reserves, annuity wish |
| Lead time | 3–6 months incl. request | Shorter |
After the conversion
The DGA framework starts: the customary salary, the corporate tax return, and the holding question — ideally answered at incorporation itself via the holding step-by-step plan. When to make the move at all: when to switch to a BV. Last verified: 19 July 2026.