The Dutch non-domiciled tax regime

Jun 15, 2023

The Netherlands offers a wholesome package with an outstanding healthcare system and a steady top ten World Happiness Index ranking.

The Netherlands has a very good physical (Schiphol, Rotterdam / The Hague and Eindhoven airports), IT, legal and tax infrastructure. What’s more, the tax system offers many benefits for individuals and companies combined with a very extensive tax treaty network. We at Migrantic tax & immigration lawyers offer a tailormade approach to your tax structure, which can be up and running in a week if necessary. Additionally, you will not risk overbilling due to our case-specific expertise and 30 years’ experience. Let us tell you how this works.

 Many people (expats, businesspeople and wealthy individuals) for example in the UK or Malta, are taxed under the favourable “non-domiciled” tax regime, whereby they are only taxed on income earned in or remitted to the country. We can achieve the same or even better result in the Netherlands!

Taxes non-domiciled regime  vs. The Netherlands
Under the ”non-dom” regime, the person who is not domiciled in for example the UK (i.e. does not have the UK as his or her “home country”) is generally only taxed on income derived in the UK or remitted to the UK. The UK is therefore a fiscal paradise for foreign (wealthy) individuals and captains of industry who do not have their domicile (roots) in the UK.

Did you know that
 the Netherlands can be a fiscal paradise for foreign wealthy individuals as well? Moreover, nationality or domicile is totally irrelevant in this Netherlands tax regime. A similar (or even better) situation compared to the UK remittance base regime can usually be set up in the Netherlands for wealthy individuals (nationality not relevant) emigrating to the Netherlands who generally speaking have not been a resident of (or close to) the Netherlands for more than 5 years in the last 25 years. Qualifying people do even not have to report their non-Netherlands source assets at all.

With the right planning and sometimes using a payrolling company, our immigration law colleagues can also arrange Netherlands work authorisation and therewith a Dutch residency permit for the entire family for non-EU and non-EEA nationals moving their residency to the Netherlands. Migrantic, lawyers for tax & global mobility can likely ensure your stay as a non-EU national in the Netherlands for at least 3 years and a majority of the cases for at least 5 years.

 Expat Tax Structure
The benefits of the Dutch facility – which has a maximum duration of 5 years – are substantial, for instance:

 1.  The migrating individual does not need report any income at all to the Dutch Tax Authority (except for Dutch source income, such as income from a Dutch company or from Dutch real estate);
2.  The individual specifically does not need to report income from investments abroad or from a foreign resident substantial interest (dividends and capital gains from closely held non-resident companies, >5% owned).

The Dutch facility requires Dutch tax planning and setting up a Dutch company but it can certainly be done.

This structure works for all persons around the world with substantial portfolio investments who are considering to move to the Netherlands and for instance are willing to do some (consultancy) work for their own company.

If this is something you would be interested in, then please contact us. If you have any other questions regarding your move or immigration to The Netherlands, don’t hesitate to call, we are happy to help.

 Please e-mail our international tax lawyer Leon van Baal on if you need further information on (the details and expenses of) this structure.