How it works
A holding owns the shares of one or more operating companies. The operating company does the daily business. It has the customers, the staff, the contracts and the risk. The holding receives the profit of the operating company as dividend. Between two Dutch BVs, this dividend is exempt from corporate tax under the participation exemption. The holding can then invest the profit, save it or use it to start another company.
The same applies when the holding sells the operating company. The holding receives the sale price free of corporate tax. The owner decides later when to take money out privately. The owner pays box 2 tax only on the amounts they take out.
A holding also separates risk. A creditor of the operating company can claim only from the operating company. The money, property and intellectual property of the holding are safe from that claim. Many owners let the holding own the office building or the brand. The holding then rents it out to the operating company.
The owner usually works for the operating company through the holding. The holding employs the owner, the director-major shareholder (DGA). It charges the operating company a management fee for this work. The holding then has one payroll and pays one salary. The customary salary is tested once.
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 operating BV pays 19% corporate tax on the remaining profit. It pays the rest to the holding as dividend, free of tax. In 2031 she sells the operating BV for €900,000. The holding receives the full amount free of corporate tax.
The figures
Every rate for 2026 is listed in Netherlands tax rates 2026, and the figures for 2027 are in Netherlands tax rates 2027.
Questions people ask
Do I need a holding from the start?
It is your choice. You can set up the holding at the start, above the operating company. The notary draws up a separate deed of incorporation for each BV. You can also add a holding later, through a share-for-share exchange. This takes more work, because you need 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. We look at this first in a written consultation.
Holdwise, Hoofddorp. We keep this definition in line with our Dutch and German glossaries, and the figures are those for the tax year 2026. Updated 30 September 2026.
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