The exemption map
| Country | Threshold | Coverage |
|---|---|---|
| Netherlands | 5% | Full, dividends and capital gains |
| Luxembourg | 10% or €1.2M | Full, with holding-period tests |
| Belgium | 10% or €2.5M + 1 year | 100% dividends-received deduction |
| Germany / France / Spain / Italy | 10–5% variants | 95%, a 5% expense add-back stays taxable |
| Ireland | Qualifying stakes | Foreign-dividend exemption since 2025; separate relief for capital gains |
| Nordics (Sweden, Denmark, Finland) | Business-related shares | Full on qualifying unlisted stakes |
| Austria | 10% + 1 year (international) | Full |
Reviewed 18 August 2026. Under a 95% regime, part of the dividend is always taxed. On €10M of dividends within a group, the 5% add-back means that €500,000 is taxable every year. Under the Dutch exemption, the taxable amount is zero.
What this means for founders
Whether a stake qualifies depends first on the threshold. Co-investments and stakes in companies with many shareholders are often between 5% and 10%. In that range, a Dutch holding qualifies, and holdings in nearby countries with higher thresholds often fall outside the exemption. See the holding explained for the background. For direct comparisons, see Luxembourg and Germany.
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.
If you live outside the Netherlands, the steps are the same in every country. An employee of the notary's office signs the deed for you with your power of attorney. The company is then registered with the KVK, the Dutch chamber of commerce, and gets its tax numbers. See company formation in the Netherlands for non-residents for an overview.
The exemption and your personal tax
The exemption at company level is one half of the plan. The other half is your personal tax. A director-shareholder (DGA) who lives in the Netherlands has a salary benchmark of €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 BV. The lower salary is what saves tax. If you lower the salary from €58,000 to €36,000, 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 the tax stays the same. Calculate it with your own figures. You pay personal tax on this money only when you take it out.