Two layers, one job each
The operating BV does the work: sells subscriptions, signs contracts, carries costs and risk. The holding does the keeping: shares, brand and code as licensed IP, and every euro of profit that can wait privately. When something goes wrong below — a claim, a failed product — everything above stays untouched.
The money flow that makes it work
Operating profit is taxed once at 19% up to €200,000 (2026), then moves up as dividend free of further tax between the companies — the participation exemption. Box 2 appears only when you take money out of the holding privately. The result is a war chest that has seen 19% tax, compounding above the risk — the engine behind the whole retention arithmetic.
Why now, and why solo
AI collapsed the cost of a second and third product toward zero — but each product is its own risk profile. The solo holding gives each one its own box when it earns it (a shared operating BV works fine until then), while you handle salary and dividend once, at the top. It is the pattern our team sets up for founders every week.
Building it: order and cost
Incorporate holding and operating BV together at the notary, put yourself on the holding’s payroll with a management agreement downward, and place the IP correctly from day one per the IP guide. The customary salary applies once, from the holding, however many companies hang below — see the salary rule. Rebuilding later around grown value is possible and always more expensive than starting right. The wider playing field is at the Netherlands for AI founders.