The route from Hong Kong
The BV comes into existence through a notarial deed, executed remotely with a power of attorney and video identification. From a Hong Kong parent, the notary asks for a recent Companies Registry extract (generally under three months old), the articles of association, passports and address proof of directors and of every person owning more than 25%, and a board resolution authorising the incorporation. Hong Kong is party to the Apostille Convention, so legalisation runs through the High Court — allow one to two weeks for that step. The KVK registration (€85,15) files in the same flow; the complete picture with documents and costs stands in the Hong Kong incorporation guide and on the BV incorporation page.
The treaty position
| Netherlands–Hong Kong tax treaty | Rate |
|---|---|
| Dividend — corporate shareholder, 10%+ of the capital | 0% |
| Dividend — other shareholders (domestic rate) | 15% |
| Interest | 0% |
| Royalties | 3% |
Rates verified July 2026. On a €1,000,000 distribution, the treaty rate keeps €150,000 within the group. The benefit attaches to arrangements with real business behind them — the treaty carries a main purpose test, so decisions, banking and a proportionate local footprint deserve design from day one; the substance guide sets out what that means in practice, and the treaty guide walks the full mechanics.
Why 2026 changed the calculation
Since 1 July 2026 the EU has withdrawn the customs exemption for consignments under €150, so direct parcels from Hong Kong carry duty per tariff heading — the shift is set out in the customs reform guide. Bulk import through a Dutch entity with an article 23 import VAT deferment licence keeps 21% import VAT off your cash flow at the border, marketplaces accept the Dutch entity for a seller account, and the product safety responsible person role is filled within the group. The full goods route stands on the e-commerce page; the market comparison on the EU market entry hub.
The structure above it
The common design keeps your Hong Kong Ltd on top: it owns the Dutch BV, which trades in Europe. Where accumulated profit and trading risk deserve separation, a Dutch holding company between the two adds the participation exemption — profits move upward untaxed at the intermediate level, and distribution onward to Hong Kong carries the 0% treaty rate. The structure guide for Asian parents compares both designs; groups running Singapore and Hong Kong entities side by side find the combined picture on the Asia structure page.
The taxes you will meet
Corporate tax at 19% up to €200.000 and 25,8% above — next to Hong Kong’s territorial two-tier profits tax of 8.25% and 16.5%, the Dutch entity buys EU presence rather than a rate. VAT runs per quarter, payroll monthly where the company employs, and the banking guide ranks the realistic account options for foreign-owned BVs. Every rate stands on the figures page and every deadline in running a Dutch BV.
Terms on this page
- BV (besloten vennootschap)
- The Dutch private limited company: a legal entity with registered shares and limited liability, so the shareholder’s private assets stay separate from business debts. Incorporation runs through a notarial deed; capital starts from €0.01.
- Apostille
- The certificate under the Hague Apostille Convention that makes an official document from one member state legally valid in another, replacing the heavier embassy legalisation chain. In the US, the Secretary of State issues it.
- Power of attorney
- The written authorisation that lets someone sign the notarial deed on the founder’s behalf. For remote incorporation the signature is legalised; from abroad an apostille is usually added.
- Participation exemption
- The rule that fully exempts dividends and capital gains on a shareholding of five percent or more from corporate tax at the receiving company. The engine underneath every Dutch holding structure.
- UBO
- The ultimate beneficial owner: the natural person who ultimately owns or controls a company, generally from a twenty-five percent interest. Registration runs through the KVK’s UBO register.
This page describes the general route for 2026; what it means for your situation follows from a personal conversation.
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