The three parts of the structure

  • The holding BV receives dividends and gains from qualifying shareholdings of 5% or more. Under the participation exemption, these are tax-free for the holding. The same holding owns the European businesses, the property BVs and the investment portfolios. See what a holding company is.
  • The STAK is a certification foundation. It owns the shares and votes on them. Family members receive certificates that give them the economic value of the shares. In your rules, you decide how control passes to the next generation. See how certification works.
  • The family foundation keeps the family charter. In the charter, the family records who makes decisions, how the branches of the family take part and how the family keeps the business together. See how family governance works.

Paying dividends to the Gulf

The holding company pays dividends to Riyadh, Dubai, Doha, Kuwait City, Manama and Muscat under the Dutch tax treaties. See the country-by-country overview. To keep these treaty benefits, the company needs real substance: a real office, local administration and written board decisions. See the substance requirements.

For a Gulf family, see the Dutch holding for Gulf owners: treaty rates, documents and your bank file.

A family member as director

A family member may live in the Netherlands and run the office as director-shareholder (DGA, the owner who also manages the BV). The normal Dutch salary rules then apply. 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 still lacks the money to pay the full salary. A prior consultation with the Tax Administration gives certainty in advance. The family member can also borrow up to €500,000 from the structure, outside box 2. The lower salary is what saves tax. With a salary of €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.

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.

Your Dutch company needs an address in the trade register. You choose that address and sign the contract yourself. See what the law asks of a business address in the Netherlands.

How most family offices start

Most family offices start with one holding company, one investment portfolio held by a custodian and two or three direct investments. Later they add property (see buying Dutch property), new businesses and companies for the next generation, all under the same holding. The yearly running costs of a family office are a five-figure amount. See the range of corporate services.

Want to keep the family wealth together? See a family office in the Netherlands, with a holding and a STAK.