The protective assessment
A substantial interest means 5% or more of the shares in a BV (besloten vennootschap, the Dutch private limited company). If you emigrate while you have a substantial interest, the tax authority issues a protective assessment. The tax authority calculates box 2 tax on the built-up value of your shares at departure. Box 2 is the Dutch tax on income from your own company's shares. Protective means that payment is deferred, interest free, for as long as you keep the shares. With this assessment, the Netherlands prevents people from building value at Dutch rates and then cashing out untaxed elsewhere a week later.
When it costs money
You pay the deferred tax when you sell the shares or distribute the reserves after leaving. As long as you keep the company and the shares, the assessment stays open. When you sell or distribute, you pay the Dutch tax that was always going to apply.
Your salary, your BV and your savings
- Salary income: ends with your Dutch employment.
- The BV itself: can continue with you abroad, though its management relocating with you shifts its tax residence. That question is the reverse side of where your company is taxed.
- Already-taxed savings: yours, wherever you take them.
Planning your departure
The orderly sequence is clear: decide the destination, check its treaty with the Netherlands, and document the management relocate. Time the distribution in the years before or after departure, depending on the two rate sets. Done in that order, an exit is a spreadsheet exercise. Done in a weekend, it is expensive. Clients worth having read the exit terms before they commit. The fuller context starts at start here.
Further reading
See also all creator questions and your first year of Dutch taxes.