How it works
A STAK separates two things that normally come together in a share: the vote and the money. The foundation owns the shares and votes at the shareholder meeting. It issues depositary receipts (certificates) to the people who paid for the shares, and passes on the dividend and the value growth to them.
That split is useful in three situations. A founder who wants to give employees or family members a share in the profit while keeping the decisions. A family business that wants to keep control in one board while the shares are spread over the next generation. And an owner who wants to keep decisions simple when there are many small investors.
The STAK has articles, a board and administration conditions that describe the rights of the certificate holders. Setting it up needs a notarial deed, like a BV. The certificates can be transferred under the conditions the STAK sets, so the founder decides who can come in.
For tax the certificate holder is treated as the owner of the shares when the certificates give them the full economic rights. The STAK itself is usually transparent, so the tax is the same as with direct ownership.
Example
A founder wants five senior employees to share in the value of the company. The STAK receives 15% of the shares and issues certificates to the five employees, 3% each. They receive 3% of every dividend and of the sale price; the founder keeps 100% of the votes through the STAK board.
The figures
All 2026 figures: Netherlands tax rates 2026 · the 2027 figures: Netherlands tax rates 2027.
Questions people ask
Who is the UBO of a STAK?
The board members are registered as UBO, and certificate holders with more than 25% of the economic interest are registered too.
Can certificates be sold?
Only under the administration conditions. Most STAKs give the foundation or the other holders a first right to buy, so the group of holders stays as the founder intended.
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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