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Emigration of a DGA (or substantial interest holder) of a BV established in the Netherlands


Once you, as a Dutch citizen, choose to live in another EU state, such as Germany, you will be confronted with the laws and regulations and also the social insurance obligation of that country. Do you have a substantial interest in a BV based in the Netherlands or are you director of that company (DGA)? Then there are fiscal consequences attached to emigration.

Alienation benefit

Fiscally, the emigration is regarded as fictitious alienation of the shares. The DGA (or AB holder) must calculate the alienation benefit. The alienation benefit is the difference between the value in the economic circulation of the shares (on the emigration date) and the acquisition price.

The value of a BV in the economic market can be much higher than the current (book) value. There may be 'silent' and also of 'not yet paid' reserves. The positive alienation benefit is not directly taxed but the tax authorities impose a conservative tax assessment and grant automatic deferment of payment. Pay attention! The limitation of the cancellation to 10 years has been abolished with effect from 1 January 2016 (with retroactive effect from 15 September 2015)!


Are you faced with the choice: emigrate yes or no? Our tips:

Calculate the alienation benefit and check whether the consequences are acceptable to you

Assess whether the location of your BV has not changed, take measures if necessary

Find out how the tax situation of your family will change, whether you have to submit an income tax return in the Netherlands and your new country of residence. And check which income is taxable in which EU state

Which changes in social security can you expect? Where are you and your family insured?

If you want to get advice on your choice or have your calculations set up, please contact us.


Nadja Elferink RB


0541-700200 n.elferink@advinez.eu