The headline rate

You choose between a Dutch BV (besloten vennootschap, a Dutch private limited company) and a company in the Emirates. The Emirates charge a low corporate rate above a high tax-free threshold, and zero tax on personal income. The Netherlands charges 19% on profit up to €200,000 and 25.8% above it. When you take money out, you also pay box 2 tax (the Dutch tax on income from your own company's shares). This is 24.5% up to €68,843 per person and 31% above it. On paper, the difference is large.

American withholding tax

For this purpose, the Emirates are outside the American treaty network. American platforms therefore withhold 30% on royalties paid to the Emirates. Dutch recipients pay zero, as explained in US withholding. For a creator with a large income from American platforms, this difference is often larger than the difference in headline rates.

Substance, in both directions

A company is taxed in the country where it is really managed. You can read more in where your company is taxed. For a company in the Emirates, you need to live there in a real sense, with an office and decisions taken locally. If the company is only a postbox and you live in Europe, your home country can claim the company, with interest.

The practical differences

  • Banking: from a Dutch base, European bank accounts and payment services are easier to open and to explain.
  • VAT (value-added tax): from a Dutch base, you report sales to European consumers from inside the EU, through the EU VAT return for cross-border sales (OSS).
  • Holding structure: under the participation exemption, your holding receives profit from a shareholding of 5% or more free of corporate tax. The same applies to the gain on a later sale.
  • Leaving again: with a European base, you keep normal treaty protection if you leave later.

Which country suits which creator

Dubai suits creators whose income comes from outside the American treaty network and who plan to live there full time. The Netherlands suits creators with American and European income, brand deals, licensing and a plan that ends in a sale. Take a lower customary salary if comparable work pays less, or for up to three years while a new BV is still unable to pay the full salary. Add borrowing 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. The full guide is in start here.