The treaty position

Under the Australian treaty, American platforms withhold five per cent on royalties paid to Australian residents. For Dutch residents, the rate is zero. On small amounts, the difference is small. It becomes important when American income is a regular part of your income. See US withholding for the details.

What you get with the Dutch structure

You use a BV (besloten vennootschap, the Dutch private limited company), with a holding company above it.

  • 19% corporate tax on profit up to €200,000 and 25.8% above.
  • Box 2 (the Dutch tax on income from your own company's shares) at 24.5% up to €68,843 per person, 31% above.
  • A loan of up to €500,000 from your own company, free of box 2 tax.
  • The participation exemption, so that your holding can later sell the company tax free. See selling your channel or brand.
  • The ruling for new arrivals: part of your salary is tax free for up to sixty months.

Leaving Australia properly

Australia taxes residents on worldwide income, so the relocation turns on ceasing residence in substance: where you live, where your family is, where your work happens. Ceasing residence has consequences for assets you own at that moment. The treatment varies by asset class. So have an Australian adviser confirm your position in good time, before the departure date.

The practical side

Time zones flip in your favour for European brand deals and against you for Australian ones, which is worth modelling before the flights are booked. Beyond that: registration, the BSN (the Dutch citizen service number), a bank account and health cover, in the order set out in relocating to Amsterdam, and the monthly arithmetic in cost of living.

Take a lower customary salary if a new BV is still unable to pay the full amount, for up to three years. A prior consultation with the Tax Administration gives certainty in advance. Also borrow up to €500,000 from your own BV. The lower salary is what saves tax. At €36,000 in place of €58,000, 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 your tax stays the same. Calculate it with your own figures. If you have American income, this is usually the first thing to arrange after you arrive. See how creators pay less tax.