The three rails
Rail one — EU directives: qualifying intercompany dividends between member states travel at 0%, conditions met and substance real. Rail two — treaties: outside the directives, the bilateral cap applies — mapped country by country in the 50-treaty library on this site, from the US to Singapore. Rail three — domestic floors: where neither reaches, the source country’s own rate stands — the map: withholding compared.
Why routes concentrate on the Dutch hub
The profile does the work: dividends in land exempt from a 5% stake, dividends out meet 15% domestic — dropping to 5%, or 0% along treaties and the EU rails — and interest and royalties leave at 0% under domestic law. One hub, three clean directions, substance as the constant: what keeps rails open.
The resident owner’s route
For the founder living here, the last leg is box 2 — 24.5% to €68,843 per person, on your timing — and the route starts earlier: as director-shareholder (DGA) you agree a lower salary in writing with the tax administration during the growth phase and borrow up to €500,000 from the own BV for private spending, together typically keeping €18,000–€20,000 per year working in the structure. Distributions then leave on your calendar, along whichever rail the chart earned: the Dutch dividend rules.