How the pieces match

  • You own the shares of Holding BV, and the holding owns Operating BV.
  • The operating BV invoices your US and EU clients; the holding collects dividends under the participation exemption at 0%.
  • Your DAFT equity of €4,500 counts as capital in the structure. When you renew the permit, the IND checks it through the annual accounts and a balance sheet or income statement.

For the basics of this structure, see what is a holding company.

Why founders choose it from the start

You have three tax advantages with this structure. Profit above your salary is taxed at 19% corporate tax up to €200,000. In your personal income tax, the same profit would be taxed at the top rate. You can build up savings in the holding, separate from the risks of the operating company. When you sell the operating company, the gain is fully exempt in the holding. You also decide when you pay box 2 tax, the personal tax on dividends paid out to you (24.5% up to €68,843, 31% above). See Dutch dividend tax 2026 for more on dividends.

Your salary as director-shareholder

As director-shareholder (DGA), you draw the customary salary of €58,000 in 2026. If the BV is just starting and still unable to pay that amount, a lower salary is allowed for up to three years. A prior consultation with the Dutch Tax Administration gives you certainty in advance. You can also borrow from your own BV. Loans up to €500,000 stay outside box 2, and you can use them for private costs. Meanwhile, the profit in the BV is taxed at 19% on the first €200,000 (25.8% above). 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 your tax stays the same. Calculate it with your own figures. If you want certainty, ask for the prior consultation early in the year. See the DGA salary rules.

US tax reporting

With two Dutch companies, you report two foreign corporations in your US tax filings. How they appear on your return depends on the elections you make. Before you incorporate, read US reporting duties with a Dutch BV and Delaware corporation and Dutch BV.

Compare the Netherlands with Ireland and Germany on tax, substance, running costs and time. See setting up a Dutch subsidiary for a foreign parent company.

More on your company

All twenty-one guides are together on the DAFT hub, grouped in the order of the steps.

Your DAFT permit, arranged with us

We arrange your DAFT application. An immigration lawyer from our network prepares it and files it with the Immigration and Naturalisation Service (IND). We set up your company and business bank account and provide the company documents your application needs. The IND decides on your permit.