Netherlands vs the UK after Brexit.

Where the UK wins

In the UK, formation takes a day. Filings are in English, under common law. London has deep venture and capital markets, and the UK treaty network is similar to the Dutch one. The UK also levies zero withholding tax on dividends paid abroad. If your market, investors and team are British, a UK company is a strong choice.

What changed with Brexit

Since the EU-UK trade agreement (TCA), there is a customs border between the UK and the EU. This means customs declarations in both directions, import VAT and paperwork for preferential tariffs. For the EU roles, you now need a company in the EU. They include the EU importer of record and the product-safety responsible person (GPSR). They also include packaging registrations (EPR), the carbon border levy (CBAM) declaration for covered goods, and the licence passports for payments and crypto. A UK company can sell to Europe. To be established in Europe, you need an EU company. For online sellers, see the UK-EU e-commerce page.

A UK company plus a Dutch BV

Many UK founders choose this setup. The UK company remains the home base and keeps the cap table. A Dutch BV becomes the operating company for the EU. The BV imports under Article 23 deferment, has the EU registrations and invoices EU customers with an EU VAT number. At 19% on the first €200,000, the Dutch company pays less tax on that profit than a UK company at the main rate of 25%. The BV can then pay dividends to the UK company free of extra tax. This is possible under Dutch rules and the Dutch-UK tax treaty. For the full framework, see where to incorporate. For the master table, see the Netherlands vs the world.

Frequently asked questions

Should I incorporate in the UK or the Netherlands in 2026?

Start with your home market. For a British business, a UK company is the best choice. A business that sells in Europe needs an EU company for customs, VAT and the EU roles that a UK company lost with Brexit. Groups that serve both markets have both companies: a UK company as the home base and a Dutch BV for the EU.

Which EU roles need an EU company after Brexit?

For several EU roles, you need a company established in the EU. These are the importer of record, the responsible person for product safety (GPSR) and the packaging registrations (EPR). They also include the declarant for the carbon border levy (CBAM) and the EU licence passports. A UK company can still sell to EU customers.

How do UK and Dutch taxes compare?

In the UK, the main rate is 25%. Small profits up to GBP 50,000 are taxed at 19%, and there is zero withholding tax on dividends. In the Netherlands, the rate is 19% up to EUR 200,000 and 25.8% above that. Dividends and exit gains are exempt under the participation exemption, and there is zero standard withholding tax on interest and royalties. On profit from EU customers, the Dutch structure usually costs less tax. For profit from UK customers, the UK company is usually the better choice.

Is the Dutch BV recognised by UK investors?

Yes. The BV is well known in UK deal practice. In the usual structure, the UK company is at the top, and the investors are on its cap table. The BV is the operating subsidiary in the EU, under the UK company.