Creators

From Canada to the Netherlands: departure tax and timing

Updated: 2026-08-17 Holdwise editorial team

Canada treats emigration as a sale. On the day you cease to be resident, most of your assets are deemed disposed of at market value and the gain is taxed, ahead of any actual sale. For a creator whose company already has value, the sequence of the relocation is the single most expensive decision to get wrong. At Holdwise, we keep this answer up to date and change it when the rules change.

The departure tax

When your Canadian residence ends, a deemed disposition applies. Your assets are treated as sold at market value on that date. You report the gain in your final Canadian tax return. Some types of assets are excluded. Shares in a private company are generally included, and a creator company usually falls in this group.

Canada taxes the value built up before your departure. The value built up afterwards is taxed in your new country. If you leave while your company is still small, the Canadian tax is small too.

What you get in the Netherlands

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: with a stake of 5% or more, the holding receives profits free of corporate tax.
Zero withholding on American royalties, the same as in Canada. See US withholding.

The right order of steps

Have the Canadian company and holdings valued while the numbers are still small.
Agree the tax treatment of your departure with a Canadian adviser, including the choice to defer payment where this is possible.
Design the Dutch structure: BV (besloten vennootschap, a Dutch private limited company), holding, salary.
Change residence, register, request the BSN (the Dutch citizen service number).
Apply for the ruling for new arrivals within four months.

Your remaining ties with Canada

To decide whether your residence really ended, the Canadian tax authorities look at your residential ties. Examples are a home you keep available, a spouse who stays behind, memberships and accounts. If you end your residence on paper and keep these ties, Canada can question your departure again. The Netherlands asks the same question the other way round. See where your company is taxed.

Take a multi-year lower customary salary, agreed with the tax authority. Add borrowing up to €500,000 from your own BV. With both, you save roughly €18,000 to €20,000 a year in the growth phase. The arrival sequence itself is in relocating to Amsterdam.

Free advice

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We help creators with their income, their company and their tax. Tell us where you stand or what you are planning. You get free advice on your next step.

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

Frequently asked questions

What is the Canadian departure tax? +

It is a deemed disposition. When your residence ends, your assets are treated as sold at market value, and you pay tax on the gain before any real sale.

Are my company shares included? +

Yes, in general. Shares in a private company are included, and a creator company is usually a private company. If you leave while the value is still small, the tax is small too.

How does Canada decide whether my residence really ended? +

Canada looks at your residential ties, such as a home you keep available, family who stay in Canada, memberships and accounts. If you end your residence on paper and keep these ties, Canada can question your departure again.