The route from Brazil
The BV comes into existence through a notarial deed, executed remotely with a power of attorney and video identification. Brazil joined the Apostille Convention in 2016, so the document side is the short version: cartório notarisation plus apostille, accepted directly by the Dutch notary within days, with a sworn translation into English for documents in Portuguese. A corporate shareholder adds a recent CNPJ registration extract and a board resolution; the KVK registration (€85,15) files in the same flow. The complete picture with costs stands on the BV incorporation page and in the non-resident setup guide — and the same story reads in Portuguese on abrir empresa na Holanda.
The treaty position
| Netherlands–Brazil tax treaty (1990) | Rate |
|---|---|
| Dividend | 15% |
| Interest | capped by the treaty, with reduced lines for qualifying loans |
| Royalties | 15% — a higher line applies to trademark royalties |
Rates verified July 2026. The treaty is one of the older ones in the Dutch network, and that makes the structure design matter more: inside the group, a Dutch holding layer moves profit upward under the participation exemption at 0% before anything crosses the Atlantic — the treaty rate then applies once, at the moment you choose. The tax optimization pillar holds the full strategy.
Services, software and trade into the EU
Two Brazilian profiles meet the Netherlands well. The first sells services and software into Europe: the BV invoices in euros across all 27 member states on one VAT number, European clients contract with an EU entity, and the São Paulo afternoon overlaps the full European working day. The second ships goods — food, commodities, consumer product — and lands them where Europe imports best: the port of Rotterdam, with an article 23 import VAT deferment licence that keeps 21% off cash flow at the border and, since 1 July 2026, the withdrawn €150 customs exemption that makes bulk import through a Dutch entity materially cheaper than shipping individually — the customs reform guide sets out the shift. The full goods route stands on the e-commerce page; the market comparison on the EU market entry hub.
BV versus Ltda.: the numbers
| Element | Dutch BV | Brazilian Ltda. |
|---|---|---|
| Minimum capital | €0.01 | Free choice, per the articles |
| Corporate tax 2026 | 19% up to €200.000, 25,8% above | ≈34% combined (IRPJ + CSLL) |
| Incorporation | 1–3 weeks, remote with video identification | Junta Comercial registration with local process |
| Market position | Inside the EU single market and VAT system | Home market and Mercosur |
The two entities do different jobs: the Ltda. runs the Brazilian and Mercosur side, the BV becomes the European leg — invoicing EU customers, importing through Rotterdam and holding the euro banking relationship via the banking route for foreign owners.
The taxes you will meet
Corporate tax at 19%, VAT per quarter, monthly payroll where the company employs, and the treaty rate at distribution — every rate stands on the figures page and every deadline in running a Dutch BV. Specialists you bring to the Netherlands can qualify for the 30% ruling.
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.
- 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.
- Corporate income tax (VPB)
- The profit tax of a BV, levied in two brackets over taxable profit per financial year. The current brackets and thresholds live on the figures page.
- 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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