The decision table
| Factor | Netherlands | France |
|---|---|---|
| Corporate tax | 19% to €200,000; 25.8% above | 25% standard |
| Dividends up & out | 0% pooling from a 5% stake; box 2 at 24.5% on your timing | 95% mother-daughter exemption; 1% for integrated groups |
| Personal layer for founders | 30% ruling on arrival; published rates, real levers | Heavy social layer; strong R&D credit and BSPCE options |
| Market & operations | EU-core logistics; English-first; deep talent | Europe’s second market; deep engineering talent |
Reviewed 18 August 2026; figures reflect common 2026 practice.
Where France genuinely wins
France wins as a market and a talent nation: the CIR research credit, BSPCE founder options and a domestic market worth being local for.
Where the Netherlands wins
The Dutch counter is structural: the exemption runs full instead of 95%, the first €200,000 meets 19%, employment law flexes, and the holding-and-treaty layer was built for international groups. The mechanics behind the Dutch column: the holding explained and substance that convinces.
The verdict per profile
Selling seriously into France: a French entity earns its place. Holding, HQ and the international layer: the Netherlands – the classic Franco-Dutch pairing, one treaty apart. Deep-dives: the 1973 treaty.