How it works
A holding owns the shares of one or more operating companies. The operating company does the daily work: customers, staff, contracts and risk. The holding stays above it and collects the profit as dividend. Between two Dutch BVs that dividend is exempt from corporate tax, thanks to the participation exemption. The profit lands in the holding untaxed and can be invested, saved or used to start the next company.
The same applies when the operating company is sold. The sale price comes into the holding free of corporate tax. The owner decides later when to take money out privately, and pays box 2 tax only on the amounts they take.
A holding also separates risk. A claim against the operating company stays there. The money, the property or the intellectual property that the holding owns stays out of reach. Many owners let the holding own the office building or the brand and rent it to the operating company.
The owner usually works for the operating company through the holding: the holding employs the DGA and charges the operating company a management fee. One payroll, one salary, one customary-salary test.
Example
A consultant earns €150,000 profit a year in her operating BV. The operating BV pays her holding a management fee, and the holding pays her a salary of €58,000. The remaining profit is taxed at 19% in the operating BV and paid up to the holding as dividend, tax-free. When she sells the operating BV for €900,000 in 2031, the full amount reaches the holding free of corporate tax.
The figures
All 2026 figures: Netherlands tax rates 2026 · the 2027 figures: Netherlands tax rates 2027.
Questions people ask
Do I need a holding from day one?
Setting up the holding together with the operating company is the cheapest moment: two deeds in one appointment. Adding a holding later is possible through a share-for-share merger, with more paperwork and a valuation.
Can a foreign company be the holding?
Yes. A company in the United States, the United Kingdom or India can own the Dutch BV directly. Whether a Dutch holding in between helps depends on the tax treaty and on where the owner lives; that is the first question in a written consultation.
Holdwise, Hoofddorp. Definition and explanation maintained with the Dutch and German glossaries; figures from the central rates source, year 2026. Updated 16 September 2026.
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