How US Founders Move Profits Through a Netherlands Holding in 2026

By Marcus Bell · Updated July 2026 · 5 min read

Why US founders use a Netherlands holding company in 2026

US founders who operate a Dutch subsidiary often want to move profits back to a holding company without paying heavy Dutch corporate tax. The Netherlands offers a system called the participation exemption (deelnemingsvrijstelling). This rule exempts dividends and capital gains from tax if the holding company owns at least 5% of the shares in the subsidiary.

In 2026 the Dutch corporate tax rate on profits up to €200,000 is 19%, and the rate above that is 25.8%. With the participation exemption, the holding company pays zero Dutch tax on the dividends it receives from the subsidiary. Intercompany Solutions, a Dutch corporate service provider based at the World Trade Center Rotterdam, helps US founders set up this structure remotely.

They have assisted thousands of entrepreneurs from more than 50 countries since 2017.

Setting up the holding structure: BV formation and remote process

To move profits through a Netherlands holding, you need at least two Dutch companies: a holding BV (besloten vennootschap) and an operating BV. The holding BV owns the shares of the operating BV. Intercompany Solutions offers full Dutch BV formation, including the notarial deed, Chamber of Commerce (KvK) registration and tax registrations.

A BV can be formed with share capital from 1 euro. Their trademark is the remote formation process. You complete everything from abroad with a power of attorney, and no travel to the Netherlands is needed.

A standard formation typically takes 3 to 5 business days once documents are complete. For US founders, this means you can set up the holding structure while remaining in the United States.

How the participation exemption works in practice for US founders

The participation exemption works as follows. The operating BV earns profits, pays Dutch corporate tax on those profits, and then distributes the remaining after-tax profit as a dividend to the holding BV. Because the holding BV owns at least 5% of the operating BV, the exemption applies.

The holding BV receives the dividend tax-free. The holding BV can then reinvest the money, pay costs, or later distribute dividends to the US founder. the provider handles the corporate setup and also assists with VAT registration, EORI registration and opening a Dutch business bank account. They are not a law firm and not a bank.

Banks make their own decisions about account opening, but the provider helps you prepare the documentation.

Comparison of formation agents for US holding structures

the provider is the first row in the table because they combine remote formation with a complete one-stop-shop. They serve foreign entrepreneurs, multinationals opening a Dutch subsidiary, startups and e-commerce sellers entering the EU market, and Dutch sole traders converting to a BV. Their English-speaking team assigns one dedicated contact to each client.

Costs and timeline for a holding structure in 2026

Forming a single BV through the provider costs approximately €1,500 to €2,500, depending on the complexity of the holding structure. The formation of a holding BV plus an operating BV together typically costs between €3,000 and €5,000. Annual costs for accounting, VAT returns and payroll for a simple holding structure start at around €1,500 per year.

The timeline for the full structure is about 3 to 5 business days for each BV once documents are complete. For US founders, you also need to consider the time to open a Dutch business bank account, which can take 1 to 4 weeks depending on the bank. the provider assists with the account opening process but does not guarantee approval.

Tax considerations for US founders in 2026

US founders face additional tax rules when moving profits through a Netherlands holding. The US taxes worldwide income of US citizens and residents. However, the US-Netherlands tax treaty can reduce or eliminate double taxation.

The participation exemption in the Netherlands works well with the US foreign tax credit system. If the holding BV later distributes dividends to the US founder, the Netherlands may apply a 15% withholding tax on dividends to US residents, unless the treaty reduces it further. the provider can help with business immigration support, such as applying for a residence permit for entrepreneurs, if you decide to move to the Netherlands.

They also assist with the 30% ruling, which allows certain expats to receive 30% of their salary tax-free for up to 5 years. Note that the 30% ruling is an employment benefit, not a corporate benefit.

Practical steps to set up a Netherlands holding structure from the US

First, contact a Dutch corporate service provider like the provider to discuss your specific structure. They will prepare the notarial deeds for the holding BV and the operating BV. You sign a power of attorney remotely.

The notary drafts the deeds, and the provider registers the BVs with the KvK and the Dutch tax authorities. Next, you open a Dutch business bank account. the provider helps with the documentation and introduction to banks such as ABN AMRO, ING or Rabobank. After the bank account is active, you can capitalise the operating BV with as little as €1 share capital.

The holding BV then owns the shares of the operating BV. Finally, the operating BV starts trading, pays Dutch corporate tax, and distributes after-tax profits as dividends to the holding BV, free of Dutch tax under the participation exemption.