What changed in the Dutch business succession relief in 2026?

From 1 January 2026, the BOR and the related rollover relief only apply to ordinary shares representing an interest of at least 5% in the company, restricting access for families with small or non-ordinary shareholdings.

Is the Netherlands introducing a tax on unrealised gains?

The Actual Return Act, passed by the House of Representatives in February 2026 and intended to take effect in 2028, would tax actual returns in Box 3, including unrealised gains on liquid assets. It still needed Senate approval as of mid-2026.

Regional Intelligence

Netherlands

Q: Why do family offices use the Netherlands for holding structures?

The participation exemption effectively shields qualifying dividends and capital gains from Dutch corporate tax, making the Netherlands a common jurisdiction for pan-European investment holding vehicles.

A mature, low-profile family office market built on centuries-old trading and industrial dynasties, with the participation exemption making it Europe's classic holding jurisdiction — now navigating a tighter business succession regime and a pending overhaul of wealth taxation.

Family Offices

50+ (est.)

Avg AUM

€500M (est.)

Regulatory Body

Authority for the Financial Markets (AFM) / De Nederlandsche Bank (DNB)

Tax Environment

Participation exemption for qualifying holdings; 25.8% corporate tax; BOR succession relief tightened from 2026, and a Box 3 overhaul pending for 2028.

Introduction

The Netherlands hosts some of Europe's oldest family enterprises, from the Fentener van Vlissingen family's SHV, founded in 1896, to the Van der Vorm family's HAL. Dutch family offices tend to be discreet and professionally run, and the country's participation exemption has long made it a default location for pan-European holding structures.

Key Numbers

Headline corporate tax rate25.8%

Box 2 top rate on substantial interests (2026)31%

Minimum interest for BOR relief (from 2026)5%

Evaluation

The participation exemption shields qualifying dividends and capital gains from Dutch corporate tax, making the Netherlands a common base for pan-European holding companies.