Nordic and Baltic companies: a Dutch holding or trading hub

What your Dutch company does, country by country

What the Dutch holding does for you

A Dutch holding company receives dividends and capital gains from its subsidiaries free of Dutch corporate tax, under the participation exemption, from a shareholding of 5%. Subsidiaries in other EU countries pay their dividends to the holding free of withholding tax under the parent-subsidiary directive; for other countries the Dutch tax treaties set the rate. The holding pays 19% corporate tax on its own profit up to €200,000 and 25.8% above that (2026). The holding counts as Dutch for tax when its decisions are taken in the Netherlands.

For a founder who brings the company along, bill 37023 changes article 7.6 of the Income Tax Act 2001 from 1 January 2027. When your company transfers its effective management to the Netherlands and you become liable to Dutch tax on the shares, the purchase price of your shares is set at their market value on that day. The Netherlands then taxes only the growth after that day as income from a large shareholding (box 2), at 24.5% up to €68,843 per person and 31% above (2026 rates). Your own country taxes the growth up to your departure under its own rules. See relocating a company to the Netherlands in 2027.

A holding also helps when you sell your business. The holding sells the operating company, receives the price free of corporate tax, and you decide when it pays you a dividend. In the meantime you invest the money inside the holding, outside the Dutch tax on private savings and investments (box 3). See the Dutch holding structure and your Dutch subsidiary.

The rules in Sweden and Denmark when a founder leaves

Sweden applies a ten-year rule, set out in chapter 3, section 19 of its Income Tax Act. A person who was resident in Sweden in the year of the sale or in the ten preceding calendar years pays Swedish tax on gains on shares. The committee directive of 25 May 2022 states that tax treaties limit this claim in many cases. The current government shut down the inquiry that this directive set up. In the Riksdag debate of 11 August 2026 the finance minister was asked about it; the government says it is preparing the question and has yet to present a bill. A Swedish founder therefore agrees the Swedish position with a Swedish adviser before setting up the Dutch holding or relocating the company.

Denmark treats shares worth more than DKK 100,000 as sold at market value on the day Danish tax liability ends. The Danish Tax Agency defers the tax when you file the tax return and the statement of your shareholdings on time. It asks for a guarantee (security) only for a departure to a country outside the Nordic agreement on help with tax collection and the EU directive on recovery of tax claims. The Netherlands is covered by that directive. Dividends and sales after departure reduce the deferred balance under the Danish rules. From 2027 the Dutch start value means that the Netherlands taxes the growth after your arrival, so each country taxes its own period.

The next step for Estonian companies and Lithuanian fintechs

Estonia taxes company profit only when it is paid out, and e-residents have founded more than 40,000 Estonian companies, one in every five new companies in the country. As those companies grow, investors and banks ask where the company is managed, where the founders live and work, and who its bank and investors are. A company managed day to day from another country can become liable to tax in that country, wherever it is registered. A Dutch holding above the Estonian company, or a Dutch operating company that employs the staff and signs the contracts, gives investors and banks the structure they ask for. We compare both systems in Netherlands versus Estonia.

Financial technology companies (fintechs) licensed in Lithuania face a similar question. At the end of 2024 the Bank of Lithuania had licensed 119 electronic money and payment institutions, which earned €622 million from licensed activities and handled €152 billion of payments. A Lithuanian licence covers the whole EU, although clients and banks in Western Europe still ask for a local office and local staff. A Dutch branch or subsidiary gives the institution Dutch payroll, a Dutch office and a Dutch company for clients to sign their contracts with, while the licence stays in Vilnius. See a Dutch entity for payments.

One Dutch company, many roles

• A holding company above your Nordic or Baltic companies, with the participation exemption and the Dutch tax treaties.
• The company that relocates with you, with the 2027 start value for your shares and 19% corporate tax on the first €200,000 of profit.
• A trading company near Rotterdam that imports goods from outside the EU with a customs number (EORI) and the Article 23 licence, and sells to EU customers on Dutch invoices.
• The company that signs Dutch defence, energy and industrial contracts, with the industrial participation agreement in its own name.
• The Dutch branch or subsidiary of a licensed fintech, with Dutch payroll and a Dutch office.
• An employer inside the EU with Dutch payroll and, from 2027, the 27% expat scheme for staff who meet the conditions.

You own the company and choose its address and directors, while Holdwise sets it up and handles the administration as an outside party. A Dutch private limited company (BV) costs from €2,950 excl. VAT, and a holding with an operating company from €4,950 excl. VAT. The notary, a valuer and your adviser in your own country charge their own fees, which you see in advance.

Sources

• Dutch Tax Administration, participation exemption (2026), corporate tax rates (2026) and box 2 rates (2026).
• Bill Other Tax Measures 2027 (37023), article 7.6 Income Tax Act 2001 (the start value for shares), rijksoverheid.nl (15 September 2026).
• Swedish Riksdag, committee directive 2022:45 (25 May 2022) on the ten-year rule and its treaty limits; interpellation 2025/26:548 and debate of 11 August 2026, in which the government says it shut down the inquiry and is preparing the question.
• Danish Tax Agency, legal guide C.B.2.14.2.8.1 deferral of the exit tax on shares, on automatic deferral when you file on time and the guarantee that applies only outside the Nordic assistance agreement and Directive 2010/24/EU; ruling SKM2024.639.BR on the DKK 100,000 limit.
• Republic of Estonia, e-Residency, half of Estonian startups involve e-residents (29 May 2026, updated 22 July 2026).
• Bank of Lithuania, EMI and PI sector: a significant leap in a year (24 March 2025).
• Government of the Netherlands, industrial participation for defence materiel, on orders above €5 million.
• Business.gov.nl, 30% ruling down to 27%, law passed, in force on 1 January 2027.

Last reviewed: 27 October 2026. Based on the official pages named under Sources, as they read on that date. The Dutch 2027 figures are from bills before parliament; the Swedish and Danish rules are as published by the Riksdag and the Danish Tax Agency on that date.