Tax advice, treaties and returns
Tax Advisor in Amsterdam for Foreign-Owned BVs and Holdings
Your BV's corporate tax, returns and payments abroad, kept on the Dutch statutory calendar, with the structure checked against its conditions.
- Return due before 1 June for a calendar year
- Filed as your tax service provider
- Advice kept apart from any address or director provider
- Tax advice: a free profession, Wwft-supervised
Corporate tax advice for a Dutch BV owned from abroad
We advise Dutch BVs and holdings whose owners or directors sit abroad on corporate income tax, the yearly return, withholding taxes, transfer pricing and rulings, from our Amsterdam office. The BV is formed through our company formation overview; its tax life is handled here, by your Dutch tax advisor.
The return is the same whether the company is a holding built through tax planning with a Dutch holding or a DAFT BV formed by a US founder. The procedure is national; international rulings come from a Belastingdienst team in The Hague. This is tax advice in the Netherlands for the company; the founders' own returns are not part of it.
What's included
Seven parts, each with the statute that sets its rule or its clock.
Corporate income tax advice
A BV incorporated under Dutch law is a Dutch taxpayer wherever its board sits (art. 2(5) Wet Vpb 1969). We apply the participation exemption, fiscal unity and the interest limits to your facts, as set out in the BV taxation guide.
The yearly return and the assessments
Every BV files each year, before 1 June for a calendar year. We check both assessments and object within six weeks where needed. Background: corporate income tax return in the Netherlands.
Dividends and withholding taxes
15% dividend withholding tax, or the exemption declared within one month. Payments to affiliates in listed low-tax jurisdictions: conditional withholding tax, 25.8% in 2026. Working tax treaties with 98 countries on 1 January 2025: the tax treaties guide.
Transfer pricing records
How each intra-group price was set, recorded for every group company (art. 8b Wet Vpb 1969). From EUR 50,000,000 group revenue, the master file and local file, in the records by the return deadline.
Advance rulings
An APA on pricing or an ATR on a transaction, such as the participation exemption. Only where the group has the economic nexus the ruling decree requires; no outcome promised.
DAC6 assessment
New cross-border arrangements checked against the EU reporting duty; a reportable one reported, as intermediary, within thirty days of the first trigger.
Representation before the Belastingdienst
Correspondence, assessments and objections, as the BV's authorised representative (gemachtigde, art. 2:1 Awb).
Where the service stops
Rules of law or scope, stated before you ask.
- Our fee is on request; the state publishes no fee for filing, extensions or objections
- Your company stays responsible for its return, whoever files it
- Books and annual accounts: bookkeeping services in the Netherlands
- Payroll returns: our payroll service; VAT numbers: our VAT registration service
- Fiscal representation: deferring import VAT with an article 23 licence
- Not the founders' own returns (M form, box 2 and 3, 30 percent ruling)
- Tax advisers, not accountants: RA, AA and accountant are protected (art. 41 Wab)
- No licence exists for tax advice; advisers are Wwft institutions, supervised by the Bureau Financieel Toezicht
- No address, director, nominee or ready-made company for a tax client or its group (art. 17 Wtt 2018: a trust office may not give tax advice)
- No ruling outcome or processing time promised
- No Amsterdam municipal tax work
How a tax year runs with us
A calendar financial year, from engagement to the final assessment.
Engagement and due diligence
The BV, its directors and beneficial owners identified before we act (Wwft); we confirm no group company takes its address or a director from us.
Authorisation and filing access
You sign an authorisation. We file through the BV's own eHerkenning (a Belastingdienst-only version exists for a foreign company) or as its tax service provider with a beconnummer (Belastingdienst).
Scoping review
Incorporation fiction, participation exemption, fiscal unity, interest limits, low-tax payments, transfer pricing, group files and DAC6, read from your group chart.
Provisional assessment kept in line
A change requested where the expected profit differs; no objection is possible, and from 2026 no paper requests.
Dividends during the year
15% withheld or the exemption declared within one month of the distribution; tax on a return paid within one month after the period.
Year end
The board draws up the annual accounts within five months, extendable by five (art. 2:210(1) BW); the master and local file go into the records by the return deadline.
The return filed
Before 1 June (business.gov.nl); five months more on the BV's request, answered within three weeks, or under becon-uitstel (the tax service provider's extension) to 30 April of the year after the normal filing year.
Final assessment and ruling
Checked against the return, with an objection within six weeks where it departs. A ruling request goes to The Hague where the economic nexus is there.
- Provisional assessment kept in lineBelastingdienst, on requestNo paper requests from 2026
- Dividend declaredThe BVWithin one month of the distribution
- Dividend tax paidThe BVWithin one month after the period
- DAC6 reportIntermediaryWithin thirty days of the first trigger
- Annual accounts drawn upThe boardWithin five months, extendable by five (art. 2:210(1) BW)
- Return filedThe BVBefore 1 June; master and local file by the same deadline
- ExtensionBV, or tax service providerTo 1 November on request; to 30 April of the year after under becon-uitstel
- Tax interest and objectionBelastingdienst; the BVInterest from 1 July if the return arrives on or after 1 June; objection within six weeks
Not sure what your structure has to file this year?
The dividend declaration, the group file and the return each run on their own clock. We map this year's from your structure chart.
Documents and access we need
What we ask for at engagement.
- Passport copies of directors and ultimate beneficial owners
- The UBO chart and the group structure chart
- KVK number, deed of incorporation and articles
- A signed authorisation to represent the BV
- Intra-group loan, licence and service agreements, with pricing basis
- Prior returns and the provisional assessment letter
- Earlier final assessments and any objections
- Dividend resolutions and the recipients' details
- Closed ledgers and the annual accounts
- Records kept for seven years (art. 52 AWR)
Dutch deadlines, rates and penalties
No state fee is published for filing; the cost sits in the sanction column.
Maxima for 2026. Penalties under the General State Taxes Act (AWR), art. 67a and 67b and the penalty decree BBBB, para. 21 and 22.
| Obligation | Deadline, calendar year | Maximum sanction or state charge | Statute |
|---|---|---|---|
| Corporate income tax return | Before 1 June | Late or missing: up to EUR 6,709; in practice half, after an unanswered reminder | Art. 67a(1) AWR; para. 21 BBBB |
| Extension of the return | Five months on request, to 1 November, reply within three weeks; or becon-uitstel to 30 April of the year after the normal filing year | No fee published | Belastingdienst; business.gov.nl |
| Tax interest | From 1 July, where the return arrives on or after 1 June | 5% from 1 January 2026 (reduced from the announced 7.5%) | Belastingdienst |
| Objection to the final assessment | Six weeks | No fee published | Art. 6:7 Awb |
| Dividend tax: exemption declaration and payment | Declaration within one month of the distribution; payment within one month after the period | 15% withheld where no exemption applies | Art. 4(11) and 5 Wet DB; art. 19(1) AWR |
| DAC6 report by the intermediary | Thirty days from the first trigger | Penalty not covered on this page | Art. 10h(1) WIBB; art. 3b(2) implementing decree |
| Notification of inability to pay VAT or payroll tax | Two weeks after the due date | Without it, directors' liability with fault presumed | Art. 36 Invorderingswet 1990; art. 7(1) implementing decree |
| VAT return | Per period | Late: up to EUR 165; standard half; none within seven days | Art. 67b(1) AWR; para. 22 BBBB |
| Payroll (wage tax) return | Per period | Late, missing, wrong or incomplete: up to EUR 1,675 | Art. 67b(2) AWR |
| Tax records | Kept seven years | Nothing | Art. 52 AWR |
The thresholds and rates the return applies to a group's BV in 2026.
2026 figures from the Corporate Income Tax Act 1969 (Wet Vpb) and the other acts named.
| Rule | Threshold or rate | Article | Act |
|---|---|---|---|
| Corporate income tax, 2026 | 19% up to EUR 200,000; above it EUR 38,000 plus 25.8% of the excess | Art. 22 | Wet Vpb 1969 |
| Participation exemption | From 5% of the nominal paid-up capital | Art. 13(2)(a) | Wet Vpb 1969 |
| Fiscal unity | At least 95%; both companies established in the Netherlands | Art. 15(1), 15(4)(c) | Wet Vpb 1969 |
| Earnings stripping | Net interest above the higher of 24.5% of EBITDA and EUR 1,000,000 is not deductible | Art. 15b(1) | Wet Vpb 1969 |
| Master file and local file | Groups with EUR 50,000,000 consolidated revenue in the preceding year | Art. 29g | Wet Vpb 1969 |
| Country-by-country report | Groups at EUR 750,000,000; within twelve months of year end | Art. 29c | Wet Vpb 1969 |
| Dividend withholding tax | 15% | Art. 5 | Wet DB 1965 |
| Conditional withholding tax | The top Wet Vpb rate: 25.8% in 2026 | Art. 4.1 | Wet bronbelasting 2021 |
| Pillar Two minimum tax | 15% for groups at EUR 750,000,000; information return within fifteen months, eighteen for the transition year | Art. 1.2, 2.1(1), 13.1(7) | Wet minimumbelasting 2024 |
Problems we solve for foreign-owned BVs
What groups ask before they hand over the file.
- "Our board sits abroad, so the BV is not Dutch-taxed"
It is: a Dutch-incorporated body is treated as established in the Netherlands. And a fiscal unity needs both companies established here, so a foreign-managed BV cannot simply join one.
- A dividend paid to the parent
The dividend tax exemption needs a declaration within one month of the distribution. To an affiliated parent in a listed low-tax jurisdiction, the conditional withholding tax applies at 25.8% in 2026.
- Intra-group prices with no paper trail
Every group company records how its intra-group prices were set; from EUR 50,000,000 group revenue, a master file and local file are due by the return deadline.
- A ruling asked for without substance
An international ruling needs operational activity and sufficient relevant staff at group level in the Netherlands, and is refused where saving tax is the sole or decisive reason (ruling decree). No processing time is published. Planning that presence: the detailed substance requirements page.
- The BV cannot pay its VAT or payroll tax
Every director is jointly and severally liable (art. 36(1) Invorderingswet 1990). Where the inability to pay is notified within two weeks of the due date, the collector carries the burden of proof; without it, fault is presumed.
Paying a dividend or interest abroad this year?
Each distribution has its own one-month declaration term, and the recipient's jurisdiction decides whether the conditional withholding tax applies.
Why work with us
Sanne Kuipers, Group structuring and tax lead, Amsterdam. Dutch, English, Spanish.
From our practice: on a new file we first check where the BV's board decides and whether any intra-group payment goes to a listed low-tax jurisdiction; both change the return and the payments abroad.
Related services and guides
Guides for the questions a return raises.
- Conditional Withholding Tax in the NetherlandsPayments to affiliates in listed low-tax jurisdictions.
Frequently asked questions
Our BV is managed from abroad: does it still pay Dutch corporate income tax?
Yes. A body incorporated under Dutch law is treated as established in the Netherlands for corporate income tax (art. 2(5) Wet Vpb 1969), wherever its board meets, and every BV files a return each year. Where the board sits still matters for a fiscal unity: it needs both companies established in the Netherlands.
Can our domicile or address provider also do our tax advice?
Not if it is a trust office established in the Netherlands: art. 17 Wtt 2018 forbids a trust office to give tax advice. The rule applies to us from the other side. We give no registered address, director, nominee or ready-made company to a tax client or to any company in its group.
If the adviser files the return, who is responsible for it?
The company. The Belastingdienst says it plainly: "You always remain responsible for your tax return." Anyone may represent a company before the Belastingdienst as its authorised representative, and the Belastingdienst may ask for a written authorisation (art. 2:1 Awb). We file and correspond for the BV; the BV supplies the facts and owns the return.
When is the corporate income tax return of a Dutch BV due, and how far can it be extended?
For a calendar financial year, before 1 June of the following year. The BV can ask for five months more before 1 June, to 1 November, and receives a reply within three weeks. A tax service provider in the becon scheme can obtain an extension to 30 April of the year after the normal filing year.
What happens if the return is filed late?
The Belastingdienst can impose a default penalty of up to EUR 6,709 for a late or missing corporate income tax return (art. 67a(1) AWR, 2026); in practice it imposes half the maximum after an unanswered reminder. Where the return arrives on or after 1 June, tax interest at 5% (2026) runs from 1 July.
Can we object to the provisional assessment?
No. A provisional assessment cannot be objected to; the BV can only ask for it to be changed when the expected profit differs, and a provisional assessment for 2026 can no longer be requested or changed on paper. The final assessment can be objected to within six weeks (art. 6:7 Awb).
What happens if the BV cannot pay its VAT or payroll tax?
Every director is jointly and severally liable for the BV's unpaid VAT and payroll tax (art. 36(1) Invorderingswet 1990). The BV notifies its inability to pay within two weeks of the due date. After a timely notification the collector carries the burden of proof; without one, the director's fault is presumed.
Can a tax adviser get us an advance ruling on the participation exemption?
An advance tax ruling (ATR) can confirm in advance whether the participation exemption applies. It is given only where the group has operational activities and sufficient relevant staff in the Netherlands, never where saving tax is the sole or decisive reason, and normally for at most five financial years. No processing time is published.
Do we need transfer pricing documentation?
Every group company records how its intra-group prices were set (art. 8b Wet Vpb 1969). A group with at least EUR 50,000,000 consolidated revenue in the preceding year also needs a master file and a local file, placed in the records by the corporate income tax return deadline (art. 29g Wet Vpb 1969).
Does our adviser have to report our structure to the tax authority?
Only if it is a reportable cross-border arrangement under the EU rules known as DAC6. The intermediary then reports it to the Minister of Finance within thirty days of the first trigger (art. 10h(1) WIBB and its implementing decree). We assess each new cross-border arrangement against that duty when it is planned.
Is a tax advisor the same as an accountant?
No. Registeraccountant (RA), accountant-administratieconsulent (AA) and the word accountant itself are protected titles under art. 41 Wab, reserved to registered professionals. An independent tax adviser works in a free profession and is an institution under the Dutch anti-money-laundering act (Wwft). We are tax advisers and do not use the accountant title.
Does a tax adviser in the Netherlands need a licence? How do I find a trusted tax advisor?
No licence exists for tax advice. The checks with a statute behind them: the adviser carries out client due diligence before acting (art. 3 Wwft), is supervised for anti-money-laundering by the Bureau Financieel Toezicht, uses no accountant title without registration (art. 41 Wab), and is not the trust office that provides your address or director.
How much does a tax advisor charge?
Our fee is on request and follows the work: the number of entities, returns, rulings and transfer pricing files. The state publishes no fee for filing a return, an extension or an objection. What it charges is for getting the calendar wrong: default penalties of up to EUR 6,709 and tax interest at 5% (2026).
What are the tax rules for expats in the Netherlands?
Individual tax is not this service. The founders' own returns, the M form, box 2 and box 3 and the 30 percent ruling are a separate field. This page covers the company: the corporate income tax of a Dutch BV or holding run from abroad, its withholding taxes, its returns and its dealings with the Belastingdienst.
Ready to hand over this year's return?
Tell us the BV's year end and its group; we reply with a proposal.
- Name
- Company
- Financial year end
- Does your company or a group company take its address or a director from us? (yes, no)
Confirmation: Thank you, we reply to the email address you gave.