The holding–operating company structure is the most used legal set-up for Dutch entrepreneurs with a BV (besloten vennootschap, the Dutch private limited company). Here is how the money flows work.
Short answer
The classic Dutch structure is two companies: an operating company (werkmaatschappij) that does the work and carries the risk, with a holding above it that owns the shares and receives the profit. Profit moves up free of tax (the participation exemption), so savings and valuable assets sit safely in the holding while the operating company trades freely. Selling later? The sale profit lands in the holding untaxed. Both companies are incorporated in one notary session — the standard advice at any serious profit level.
The money flows in a holding structure
Operating BV → Holding: the operating company earns profit, pays corporate tax (19% up to €200,000), and distributes the net result as dividend to the holding — tax-free through the participation exemption.
Holding → DGA private: the holding distributes dividend to you privately. Box 2: 24.5% up to €68,843, 31% above (2026).
Intermediate and sub-holdings
Larger groups sometimes add an intermediate holding for specific regions or activities. For most SME entrepreneurs, one holding above the operating companies covers everything.
The advantages in full: what a holding structure delivers; the salary route through the structure: DGA salary via the holding. Last verified: 19 July 2026.
Read next
This question continues in Holding with Multiple Operating Companies and in Holding via Stichting (STAK).
Frequently Asked Questions
Can I hold multiple operating companies under one holding? +
Yes. The holding can own shares in any number of operating BVs — the standard structure for active groups.
How does profit flow from operating BV to holding? +
Through a dividend resolution, tax-free via the participation exemption at a stake of 5% or more. The distribution test of article 2:216 comes first.
How many operating companies fit under one holding? +
Unlimited. Each activity with its own risk profile gets its own operating BV; the holding pools the profits and the wealth. Every extra BV does add its own administration and annual accounts.
Does a fiscal unity share the 19% first bracket? +
Yes: consolidated BVs share one €200,000 bracket. Independently taxed BVs, each running a genuine business, each carry their own bracket — a deliberate choice at structural profits above two tonnes.
