From the USA

US Family Asset Structures and Dutch Taxation: What Owners Should Know

Updated: 18 August 2026 Holdwise editorial team USA Family assets Tax

The Netherlands taxes most family asset structures under one regime. The separated private assets regime (APV, afgezonderd particulier vermogen) attributes the wealth and income of the structure to the settlor, the person who placed the assets. After the settlor dies, it attributes the assets to the heirs. Owners who know this before they move avoid a surprise. Holdwise keeps this answer up to date and changes it when the rules change.

How the APV rule works

A common-law family fund places assets with a fiduciary, who manages them for the beneficiaries. Dutch tax law treats a discretionary family fund as transparent for tax purposes. It attributes the assets, income and gains to the person who contributed them. A US grantor arrangement is taxed where its settlor is taxed. If you relocate to the Netherlands, the portfolio of the fund typically appears on your own Dutch tax return, usually in box 3. Box 3 taxes a deemed return at 36% above a per-person exemption of €59,357 in 2026.

What this means per role

Settlor moving to NL: plan the box 3 position of the fund portfolio alongside your other assets. The attribution is personal.
Beneficiary moving to NL: distributions are taxed, and after the settlor's death, attributed shares are taxed too. Map the family tree against the rule early.
Fund owning a business: operating companies owned by a family fund fit well into Dutch holding structures. This is a good time to modernise: the holding alternative.

Dutch instruments that do similar work

Dutch practice can separate control from economic value using corporate tools. Certification through a foundation keeps decision power with the principals, while the family keeps the economic benefit. Holding structures support succession across generations, as the family-office article explains: the Dutch approach. US estate planning continues to operate at home. The Dutch structure is designed separately, so the two work together.

What a group needs for a Dutch entity, how long it takes and what the parent must sign: setting up a Dutch subsidiary.

The one session that pays for itself

Before the move, list every family asset structure with its contributors and beneficiaries. Run the APV attribution for each one. Decide per structure whether to keep it, restructure it or distribute it. One coordinated session between your US estate counsel and a Dutch advisor settles a decade of returns: the wider two-system view.

Advice, free of obligation

Would you like our team to take a look at your situation?

Tell us where you stand or what you’re planning. Our team replies with advice, free of any obligation.

Part of Doing Business in the Netherlands, the complete 2026 guide.

Frequently asked questions

How does the Netherlands tax my revocable family arrangement? +

The APV regime attributes its assets to you. They appear on your Dutch return as your own, exactly as they do on your US return. Plan your box 3 position around that portfolio early.

Are distributions from a family fund to a Dutch-resident child taxed? +

Attribution decides the answer. Wealth attributed to a Dutch resident is taxed as theirs. Distributions within that attribution are money already taxed once, so they are not taxed again. Outside attribution, gift-tax questions can arise. Map each beneficiary separately.

Does the Netherlands recognise these structures legally? +

Yes. The Netherlands recognises them under the Hague framework for civil purposes. The APV regime only sets the tax treatment. Contracts, ownership and administration continue to work as before.

Sources Belastingdienst · KVK · wetten.overheid.nl Last updated: 18 August 2026