Launch Your Netherlands
Holding Company
A Dutch holdco that uses the participation exemption properly.
The Dutch participation exemption is the gold standard of holding regimes, but it only holds with genuine substance and clean flows. Orbit incorporates the entity, runs the books, keeps distributions clear of the 25.8% conditional withholding trap, and prepares the Form 5471 and earnings and profits tracking your United States tax preparer needs.
Key Jurisdiction
Considerations
Setting up a corporate entity in the Netherlands comes with standard regulatory compliance items. Orbit ensures complete legal alignment with Chamber of Commerce and Dutch tax authority requirements from day one.
100% Fully Managed Support
From resident nominee directors to local corporate secretary requirements, we cover every compliance checkpoint seamlessly.
Tax on qualifying dividends and gains
The participation exemption (deelnemingsvrijstelling) makes both dividends and capital gains from a qualifying 5% or larger shareholding fully exempt, with no holding-period requirement. Many regimes cover only one.
DTAs, including the United States
A vast treaty network plus the EU directives make the Netherlands the classic conduit for European investment flows, reducing withholding at source. The United States treaty is in force and carries a Limitation on Benefits article, so substance decides whether you can use it.
Resident directors required by law
None is required by statute, but genuine local board presence and decision-making are expected to secure treaty benefits and tax residency.
Top corporate rate
The headline rate (19% up to EUR 200,000) rarely bites a pure holding company, whose main income, qualifying dividends and gains, is exempt.
Quick Facts
| Feature | Value | Why it matters |
|---|---|---|
| Best for | EU-centric holding company, private equity platforms, multinational groups | Premier EU credibility |
| Setup speed | About 5 to 10 business days (notary deed) | Predictable process |
| Minimum share capital | About EUR 0.01 (B.V.) | Very low capital |
| Local director needed | Not by law, but substance is expected | Needed for treaty benefits |
| Company secretary | No | Lower admin |
| United States income tax treaty | In force, with a Limitation on Benefits article | Substance is what makes the treaty usable |
EU-centric holding company, private equity platforms, multinational groups
Premier EU credibility
About 5 to 10 business days (notary deed)
Predictable process
About EUR 0.01 (B.V.)
Very low capital
Not by law, but substance is expected
Needed for treaty benefits
No
Lower admin
In force, with a Limitation on Benefits article
Substance is what makes the treaty usable
What’s Included & Pricing
Complete transparency. Review what is covered under our standard package and how our tailored corporate pricing is structured.
Standard Package Inclusions
- Incorporation via licensed registered agent
- Registered agent and registered office
- Annual government compliance
- Economic substance and annual return filing
- Accounting and recordkeeping
Tailored Transparent Pricing
We tailor pricing based on your business profile, structure, and scope of services. Costs are discussed and confirmed after a quick review of your requirements, ensuring you only pay for what you actually need.
Why Netherlands Works for Holding Companies
Participation Exemption
Participation exemption on dividends and capital gains from qualifying subsidiaries.
Treaty Power
An extensive double tax treaty network, roughly 100 or more treaties, reduces foreign withholding.
Stable EU System
A stable EU legal system and a robust financial services ecosystem.
Institutional Favorite
A commonly accepted jurisdiction for institutional investors and holding structures.
EU Directive Coverage
Covered by the EU Parent-Subsidiary and Interest and Royalties Directives.
Tax Regime For Holding Companies
Corporate income tax
19% up to about EUR 200,000 and 25.8% above.
Participation exemption
Exempts dividends and capital gains from qualifying subsidiaries (5% or more ownership, non-portfolio, and a subject-to-tax test).
Withholding tax on dividends
15% statutory, reduced or exempt under treaties or EU directives with sufficient substance.
Capital gains tax
None on qualifying share disposals.
Interest and royalty withholding
Targeted anti-abuse rules may apply in low-tax or artificial arrangements, including a 25.8% conditional withholding tax.
United States owner treatment
A Dutch company owned more than 50% by United States shareholders is generally a Controlled Foreign Corporation. Income can be picked up under Subpart F or GILTI, Section 245A may apply to qualifying dividends, and Form 5471 is filed with the United States return. Where an existing United States group is being placed under a Dutch holdco, Section 7874 anti-inversion rules should be checked before anything is filed.
Corporate Tax Calculator
Estimate corporate income tax under the Dutch two-bracket regime.
19% applies up to EUR 200,000 and 25.8% above. Qualifying dividends and gains are exempt under the participation exemption. United States owners should model the Subpart F, GILTI, and Section 245A position separately.
What You Get With Orbit
A fully managed, end-to-end statutory solution for international corporate holdings.
Pre-incorporation planning
Structure design, participation exemption validation, and treaty mapping, including a Section 7874 sanity check where a United States group already exists.
Incorporation
Notary coordination, registration, and Chamber of Commerce filings.
Substance and governance
Local director, board meetings, minutes, and ongoing oversight.
Accounting and compliance
Bookkeeping, management accounts, and annual corporate income tax filings.
Residency and treaty filings
Tax residency certificate and treaty documentation support.
United States reporting support
We assemble the Form 5471 package, earnings and profits schedules, and treaty documentation your United States preparer needs. Filing and IRS representation are handled by licensed United States tax partners.
Audit coordination
For medium and large entities with mandatory reporting.
How The ProcessWorks
A highly structured compliance timeline tracking setup steps from day zero kickoff to annual filings.
Kickoff and KYC (Day 0)
Collect documentation and confirm structure and shareholding.
Notarial incorporation (5 to 10 days)
Prepare and execute the deed with a civil law notary.
Registration
Complete Chamber of Commerce filings and obtain the company number and VAT registration.
Substance setup
Assign a local director, establish the office, and activate the governance framework.
Go-live
Banking, tax registration, and treaty or trading readiness.
Annual compliance
Accounts filing, corporate income tax return, board meetings, and renewal, with the Form 5471 package prepared on the same cycle.
What we need from you
KYC documents for shareholders and directors.
Ownership chart and intended holding structure.
Business purpose and funding flow overview.
United States shareholder details and ownership percentages for Form 5471 scoping.
Substance requirements (director, office, or full-service package).
Who this is ideal for
EU-centric holding company
Private equity platforms
Multinational groups
Tell us your use case
Ready to get started?
Trusted by high-
growth organizations
"I've been working with Orbit since the beginning of 2026 and couldn't be happier. They are professional, detail-oriented, responsive, and always timely. As the owner of a one-person corporation, I greatly appreciate having such a reliable accounting team in my corner. Highly recommended!"
Maja Djikic
Consultant
Global Entity Management Pricing
Treaty Power and Substance
Netherlands Holding Company
Global Entity Management Service
Pricing
Custom Pricing
Setup fee plus annual management fee per entity. Multi-entity discounts available.
A globally respected EU platform with world-class treaty access and the powerful Dutch participation exemption.
Jurisdiction Quick Facts
Why Netherlands Works
- Dutch participation exemption on qualifying dividends and gains
- World-class double tax treaty network
- Strong EU credibility for investment flows
- Clear path to tax residency with proper substance
Standard Package Inclusions
- Incorporation via licensed registered agent
- Registered agent and registered office
- Annual government compliance
- Economic substance and annual return filing
- Accounting and recordkeeping
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Frequently Asked Questions
Not legally, but it is essential for tax residency and treaty benefits.
No, as little as EUR 0.01 for a B.V.
Generally exempt under the participation exemption.
15%, often reduced or nil via EU or treaty relief.
Only if the company exceeds size thresholds.
Only if you make taxable supplies.
No. The treaty is in force but carries a Limitation on Benefits article, so genuine substance and qualifying ownership are what make it usable.
No. Orbit prepares the books, the Form 5471 package, and the supporting schedules. Filing and IRS representation are handled by licensed United States tax partners.