Why multiple operating companies
Each activity with its own risk profile earns its own BV (besloten vennootschap, the Dutch private limited company): a webshop next to consultancy, real estate next to operations, a risky venture next to the cash cow. A failure in one BV stays in that BV; the holding and the sister companies stand apart.
The money flows
Each operating BV pays corporate tax over its own profit and distributes the remainder to the holding — 0% through the participation exemption at 5%+ stakes. The holding pools the wealth and pays your salary via the management fee under the pass-through scheme.
The key choice: fiscal unity or separate
| Fiscal unity | Separately taxed | |
|---|---|---|
| €200,000 bracket at 19% | One, shared | One per BV with a genuine enterprise |
| Loss relief between BVs | Direct | Stays per BV |
| Internal supplies | Invisible for corporate tax | At arm’s length |
| Liability for corporate tax | Joint | Per BV |
At structural profits above €200,000 across the group, separate taxation multiplies the 19% bracket — weighed against the unity’s loss relief. The mechanics: fiscal unity explained; intercompany financing: loans from holding to operating BV. Last verified: 19 July 2026.