The exit tax
Spain taxes unrealised gains on relevant participations when the holder transfers tax residence abroad. For a creator whose company already has value, that means a bill in a year when the proceeds are still to come. The approach: know the value, choose the moment, and build the Dutch structure afterwards. Leaving early means relocating while the shares are still worth little.
Regional wealth tax
In Spain, wealth tax differs a lot between the autonomous communities, and the state tax on large fortunes comes on top. The Dutch equivalent is box 3 (the Dutch tax on private savings and investments). The rate is 36% on a notional return, with an exemption of €59,357 per person. For many creators, this comparison is more important than the corporate tax rate.
The Beckham regime and the Dutch expat ruling
The Spanish regime for new arrivals is built around an employment relationship, which makes it awkward to match around the life of an independent creator. The Dutch version works differently. It exempts 30% of salary in 2026, and 27% for new cases from 2027, for up to sixty months. It is applied for by your employer, which can be your own BV (besloten vennootschap, a Dutch private limited company).
What applies here
- 19% corporate tax on profit up to €200,000, 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.
- A wide network of tax treaties, which is very important for royalties and advertising income from abroad.
The order, in practice
- Have the Spanish shares valued.
- Design the Dutch structure: BV, holding, salary.
- Change residence, register, request the BSN (the Dutch citizen service number).
- Transfer contracts and payouts across.
- Apply for the ruling within four months.
A multi-year lower customary salary, agreed with the tax authority, can combine with borrowing up to €500,000 from your own BV. Together they save roughly €18,000 to €20,000 a year in the growth phase. The arrival is in relocating to Amsterdam and the city comparison in Amsterdam or Barcelona.
Related articles
You can read more in questions from creators and in where your company is taxed.