Gulf & Energy Economies

A Dutch Holding for Your Gulf Group: Treaty-Protected Dividends

Updated: 18 August 2026 Holdwise editorial team Gulf Holding GCC

Many Gulf groups hold their European companies through a Dutch holding company. Under the participation exemption, the holding pays 0% corporate tax on dividends and capital gains from qualifying shareholdings of 5% or more. The Netherlands also has tax treaties with all six Gulf Cooperation Council states. You decide how the holding pays out the profit before you invest the first euro. At Holdwise, we keep this answer up to date. You find the steps further down this page.

What the holding does for a Gulf group

Receives the European profits: the holding receives dividends tax-free from operating BVs, property companies and other companies in which it has a stake of 5% or more.
Sells free of extra tax: when the holding sells a European subsidiary, the gain is tax-free for the holding. The group can then invest the money again or pay it out when it chooses.
Pays out to the Gulf: the holding pays dividends to the parent company or the family in the Gulf under the tax treaties. See the rates and rules per country.

For the basics, see what a holding company is.

What substance the holding needs

To get treaty benefits, the holding needs a real presence in the Netherlands. That means a real office, local administration and board decisions taken in the Netherlands. The requirements are practical. See the substance checklist, the formal requirements and substance and treaty access.

Paying dividends to the Gulf? See the Dutch holding for Gulf owners and families, with the treaty rates per country.

Salary and loans for the owner-director

An owner may live in the Netherlands and run the holding as director and major shareholder (DGA). You then have choices under the salary rules. The standard salary is €58,000. A lower salary is allowed if comparable work pays less, or for up to three years while a new BV is still unable to pay that amount. A prior consultation with the Tax Administration gives you certainty in advance. You can also borrow up to €500,000 from your own structure outside box 2. Box 2 is the personal tax on dividends and on gains from a substantial shareholding. 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 its tax saving is zero. Calculate it with your own figures. Meanwhile, the group profits are taxed at the corporate tax rate. If you want certainty, ask for the prior consultation early in the year.

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.

The steps, in order

First you set up the holding company, remotely, with a power of attorney. See setting up from abroad. You add operating and property companies below it when you need them. You open the bank account with a prepared file. See banking for Gulf owners. A Dutch service provider then takes care of the deadlines. See registers and filings.

Free advice

Want our team to have a look?

We help you set up your company or holding in the Netherlands, from the notary to your tax numbers. Tell us where you stand or what you are planning. You get free advice on your next step.

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

Frequently asked questions

Does the participation exemption cover our GCC operating companies too? +

Yes. The exemption applies to qualifying stakes of 5% or more in active companies, in any country. Dividends from Gulf subsidiaries to the Dutch holding can therefore be tax-free. Each Gulf country applies its own rules to dividends paid abroad.

How many entities does a starter group need? +

Usually two: a holding company and one operating BV. You can add property companies, new ventures and family companies to the group later. For each new company, the notary draws up a new deed. The existing structure stays the same.

What does the holding cost to run properly? +

Usually a few thousand euros per year. You pay this for the bookkeeping, the filings and regular board meetings. The business address is a separate cost under a contract that you sign yourself. One tax-free dividend is often much larger than these costs. See corporate services for the full breakdown.

Sources Belastingdienst · KVK · wetten.overheid.nl Last updated: 18 August 2026