From Norway to the Netherlands as a business owner: wealth tax, exit tax and your Dutch BV
Norway taxes the value of a business owner’s shares every year, at up to 1.1%, and taxes the gain on those shares when the owner leaves the country. The Netherlands taxes the owner of a Dutch private limited company (BV) only when money comes out of the company, and a bill before parliament would, from 1 January 2027, let a newcomer start with the market value of the shares on the day of arrival. Because both countries tax the same relocation, an owner who plans it needs the figures of both for 2026 and 2027.
Ask about your situationIn 2026 Norway taxes net wealth above NOK 1,900,000 at 1.0% and above NOK 21,500,000 at 1.1%, counting shares at 80% of their value, and taxes dividends and share gains at 37.84%. An owner who leaves Norway pays the same 37.84% on the gain on his shares above NOK 3,000,000, with up to 12 years to pay. The 2027 budget of 7 October 2026 proposes to keep these rates and to raise the threshold to NOK 1,990,000.
The Netherlands levies zero yearly tax on the shares in your own BV. The BV pays 19% corporate tax on profit up to €200,000 and 25.8% above that, while you pay the Dutch income tax for owners of 5% or more (box 2) only on dividends and on a sale, at 24.5% up to €68,843 per person and 31% above that in 2026. Money kept inside the BV falls outside the Dutch tax on private savings and investments (box 3). From 1 January 2027 a bill would set the starting value of your shares at their market value on the day you become a Dutch taxpayer (the step-up), so the Netherlands taxes only the growth after your arrival, while the Norwegian exit tax remains a Norwegian matter that we work out with your Norwegian adviser.
Tell us what you make or sell, where your company is and what you plan in Europe. Our team looks at it and replies with the steps and the dates that apply to you.
Who does what
We set up and manage your Dutch company and your Dutch tax position, with one contact person. Your Norwegian adviser keeps the Norwegian side. Each partner price is shown to you first.
Your company
- Your Norwegian company, your shares and your family
- The decision on the relocation, the date and the structure
- The Norwegian exit tax return, with your Norwegian adviser
The Dutch company
- Your Dutch holding or relocated company, set up by power of attorney with the notary
- The Dutch tax picture for you and the company, with box 2, box 3, corporate tax and the 2027 step-up
- Bookkeeping, corporate tax returns, dividend tax returns and payroll
- The link with your Norwegian adviser, so both returns match
Norway, notary, valuation
- Your Norwegian tax adviser for the exit tax and the Norwegian return
- Notary for the holding and for a share transfer
- Valuer for the market value on the day of departure and arrival
Step by step
From a Norwegian owner with a yearly wealth tax bill to a Dutch resident with a Dutch holding.
- Your figures. You share the value of your shares, your acquisition price, your dividend plans and your preferred date. Our team replies with the Dutch picture and the points for your Norwegian adviser.
- The structure. Together with both advisers, you choose between a holding above your Norwegian limited company (AS), relocation of the company and a sale.
- The Dutch company. The notary sets up your holding by power of attorney once the documents are complete.
- The dates. You fix the date of departure from Norway and the start of Dutch tax liability, in 2027 if you want the step-up.
- Afterwards. Bookkeeping, tax returns, dividend planning within the box 2 bands, and the twelve-year Norwegian schedule in your calendar.
Norway 2026 against the Netherlands 2026 and 2027
| Tax | Norway 2026 (law; 2027 budget is a proposal) | Netherlands 2026 (law) | Netherlands 2027 (bill) |
|---|---|---|---|
| Yearly tax on wealth | 1.0% on net wealth above NOK 1,900,000 (double for spouses), 1.1% above NOK 21,500,000. Shares and business property count for 80%, operating assets for 70%. For 2027 the budget proposes a threshold of NOK 1,990,000 and the same rates. | Zero on the shares in your own BV. Private assets above €59,357 per person are taxed in box 3 at 36% on a fixed assumed yield (deemed return) of 6.00% for investments, which is 2.16% of the value. | Box 3 tax-free amount €60,098 in the bill; deemed return on investments 6.37%, which is 2.29% of the value. Shares in your BV stay outside box 3. |
| Dividend and share gains | 37.84%: 22% on the amount multiplied by 1.72. Including the 22% company tax, 51.5% of the profit. | Box 2: 24.5% up to €68,843 per person, 31% above. A tax partner (spouse or registered partner) has the same band. | 24.5% up to €69,703 per person, 31% above in the bill; 29.2% announced for 2027 to 2030, still to be put into a bill. |
| Tax when the owner leaves | Exit tax at 37.84% on the net gain above NOK 3,000,000, fixed on the day you leave. Payment within 12 years, at once, in interest-free yearly instalments, or at the end with interest. A dividend ends the deferral for 70% of that dividend. The tax lapses if you return with the shares within 12 years. | For a newcomer, the historical acquisition price of the shares applies when the company relocates in 2026. | Step-up: the acquisition price of your shares is set at market value on the day your Dutch tax liability starts, so only the growth after that day is taxed in the Netherlands (bill 37023, 1 January 2027). |
| Company tax | 22% (unchanged in the 2027 proposal). | 19% on profit up to €200,000, 25.8% above. | 19% and 25.8%, unchanged in the bill. |
| Dividend from the Norwegian company to the Netherlands | Tax treaty Netherlands-Norway, in force since 30 November 2013: zero Norwegian withholding tax (tax taken off the dividend at source) when a Dutch company owns at least 10% of the capital directly; at most 15% in other cases, credited against Dutch tax. Norway may tax your gain on the shares in a Norwegian company for five years after you leave (article 13, paragraph 5). | ||
Take an owner with shares worth NOK 100,000,000 and private assets below the threshold. Norway counts the shares at 80%, or NOK 80,000,000, and charges 1.0% on the band from NOK 1,900,000 to NOK 21,500,000 and 1.1% above it, which comes to NOK 839,500 a year before any dividend. The same shares in a Dutch BV owned by a Dutch resident are subject to zero yearly tax, and box 2 applies only when the BV pays a dividend.
What Norway charges when you leave
Norway fixes the exit tax on the day your tax residence ends. The base is the net gain on your shares, measured from your acquisition price to the market value on that day, and only the part above NOK 3,000,000 is taxed, at the ordinary rate of 37.84%. The rules apply to departures from 20 March 2024, and the dividend rule applies to departures from 7 October 2024 (Lovvedtak 17, 2024-2025).
You choose to pay at once, in twelve equal yearly instalments free of interest, or in one amount after twelve years with interest. A dividend paid during those years ends the deferral for an amount equal to 70% of that dividend. If you die, your heirs may take over the obligation. If you return to Norway with the shares within twelve years, the tax lapses. For a departure to a country in the European Economic Area, the Norwegian Tax Administration asks for security only where there is a real risk that the tax stays unpaid.
Norway applies this rule to every departure, whether the owner relocates to Switzerland, Spain or the Netherlands and whichever adviser he uses. On the Dutch side, the questions are what you pay after arrival and how the two countries treat the same shares, and we work this out together with your Norwegian adviser so that the Norwegian and Dutch returns match. Norwegian owners often search for this as "flytte til Nederland med selskap" or "formuesskatt Nederland".
Tell us what you make or sell, where your company is and what you plan in Europe. Our team looks at it and replies with the steps and the dates that apply to you.
What the Netherlands charges after your arrival
A Dutch resident who owns at least 5% of a company pays box 2 tax on dividend and on the gain at a sale, at 24.5% on the first €68,843 per person in 2026 and 31% above that, and pays zero yearly tax on the value of those shares. The company itself pays Dutch corporate tax on its profit once it is managed from the Netherlands, at 19% up to €200,000 and 25.8% above.
Under current law the Netherlands uses your historical acquisition price, so a later sale in the Netherlands would tax the growth from your Norwegian years again, with a credit for the Norwegian exit tax. Bill 37023 changes that for a Dutch tax liability starting on or after 1 January 2027 by setting the acquisition price of your shares at their market value on that day, so that Norway taxes the growth up to your departure and the Netherlands the growth after your arrival. An owner with a large gain therefore does better to become a Dutch resident in 2027, after the Senate has voted in December 2026. See relocating a company to the Netherlands in 2027.
Box 3 taxes private savings and investments above €59,357 per person (2026) at 36% of a fixed assumed yield, which is 6.00% for investments. Money kept inside your holding BV falls outside box 3, and the BV pays corporate tax on its real result. For 2027 the bill sets the tax-free amount at €60,098 and the assumed yield on investments at 6.37%, against 1.0% or 1.1% a year on 80% of your shares in Norway. See the Dutch wealth tax in 2027.
If you take a salary from your own Dutch BV and meet the conditions, the expat scheme (the Dutch tax break for employees recruited from abroad) makes 27% of your salary tax-free for five years from 1 January 2027 (law, adopted). The required salary is €50,436 in 2024 amounts, indexed each year. The Dutch tax office (Belastingdienst) decides each application on its own facts, which matters most for an owner whom his own company recruits from abroad.
How owners use the Dutch BV
A Dutch holding can own the shares in your Norwegian limited company (AS). Dividends from the AS to the holding are free of Norwegian withholding tax under the treaty when the holding owns at least 10% directly, and free of Dutch corporate tax under the Dutch exemption for dividends from subsidiaries (participation exemption), so you decide when the holding pays you. The holding is Dutch for tax purposes provided its decisions are taken in the Netherlands.
Your company can also relocate with you. Once its management transfers to the Netherlands, the company becomes Dutch for tax and, from 2027, the step-up applies to your shares, while the Norwegian exit tax applies on the day you leave, with the twelve-year payment plan.
If you plan to sell your Norwegian company, the order of the steps decides the tax. Norway taxes a sale before departure at 37.84%, while for a sale after departure the exit tax covers the gain up to your departure and Dutch box 2 the growth after arrival. Your Norwegian adviser and our team work out the two returns together before you decide.
See the Dutch holding structure and a family office in the Netherlands for the long-term set-up.
One Dutch company, many roles
The same Dutch BV can act as the holding company above your Norwegian AS and your other companies, with the participation exemption and the treaty rate of 0% on dividends from a 10% participation. It can be the company you relocate, with the 2027 step-up on your shares and 19% corporate tax on the first €200,000 of profit, and it can serve as your investment company, because money inside the BV falls outside box 3 and is taxed on its real result. It can also employ you in the Netherlands, with payroll and, where the conditions are met, the 27% expat scheme from 2027, and act as your EU trading company if your Norwegian business also sells into the EU. See Norwegian exporters and the EU.
The company, the address and the directors are yours, and Holdwise sets up and manages the company while the ownership remains entirely with you. Your Dutch company (BV) costs from €2,950 excl. VAT, and a holding with an operating company from €4,950 excl. VAT. The Norwegian adviser, the notary and a valuer have their own price, which you see first.
Sources
- Norwegian Tax Administration (Skatteetaten), wealth tax rates (2026), with 0.35% municipal and 0.65% state above NOK 1,900,000, 0.75% state above NOK 21,500,000, thresholds doubled for spouses; valuation discounts 2026, with shares and business property 20%, operating assets 30%.
- Skatteetaten, factor for upward adjustment of gains and dividends on shares (2026), with factor 1.72, rate 37.84%.
- Norwegian Government (Regjeringen), tax rates 2027, proposal (budget of 7 October 2026), with threshold NOK 1,990,000, rates unchanged, company tax 22%.
- Norwegian parliament (Storting), Lovvedtak 17 (2024-2025), Tax Act section 10-70, with the NOK 3 million threshold, 12 years, the 70% dividend rule, lapse on return, heirs; effective for departures from 20 March 2024 and 7 October 2024.
- Regjeringen, press release on the exit tax rules (20 March 2024), with three payment options and only growth during Norwegian residence taxed.
- Skatteetaten, guideline on deferral of exit tax, security within the EEA only where there is a real recovery risk.
- Tax treaty Netherlands-Norway, wetten.overheid.nl (in force from 30 November 2013), article 10 (15%, 0% at 10% participation and for pension funds), article 13 paragraph 5 (five years).
- Dutch Tax Administration, box 2 rates (2026), box 3 calculation (2026), corporate tax rates (2026) and participation exemption.
- Bill Other Tax Measures 2027 (37023), article 7.6 Income Tax Act 2001 (step-up), rijksoverheid.nl (15 September 2026); the 2027 tax figures table (fiscale sleuteltabel) at rijksoverheid.nl.
- Business.gov.nl (Netherlands Enterprise Agency), 30% ruling down to 27%, law passed, 1 January 2027, salary norm €50,436.
Last reviewed: 27 October 2026. Norwegian figures from Skatteetaten, Regjeringen and the Storting; Dutch figures from the 2026 rates and the bills before parliament for 2027. The 2027 figures on both sides are proposals until the Storting and the Dutch Senate have voted.
What we arrange beyond the company
Once your Dutch company is set up, we can help you with more. When you win a Dutch defence order, the government asks you to place part of the work with Dutch companies, and we find those companies for you. We prepare subsidy applications for your company, such as the Dutch subsidy for renewable energy and climate projects (SDE++) and the tax credit for research and development (WBSO). We help you buy a Dutch contractor or supplier, and we arrange export credit insurance and project finance with the banks.
We agree every fee with you first and link it to the result. For a project that deserves it, we join as co-founder and take a share of 5 to 10% in the project company.
Common questions
Want our team to have a look at your relocation?
Tell us what your company is worth, when you want to leave Norway and whether a sale is planned. Our team replies with the Dutch picture and the points to settle with your Norwegian adviser.
Related guides
More for owners who relocate to the Netherlands.