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Netherlands
The Dutch United Provinces declared their independence from Spain in 1579;
during the 17th century, they became a leading seafaring and commercial power,
with settlements and colonies around the world. After a 20-year French
occupation, a Kingdom of the Netherlands was formed in 1815. In 1830 Belgium
seceded and formed a separate kingdom. The Netherlands remained neutral in World
War I, but suffered invasion and occupation by Germany in World War II. A
modern, industrialized nation, the Netherlands is also a large exporter of
agricultural products. The country was a founding member of NATO and the EEC
(now the EU), and participated in the introduction of the euro in 1999.
The
Netherlands has a long history of international business activity dating back to
the beginning of the 17th century and the formation of the Dutch East India
Company (Vereenigde Oostindische Compagnie or VOC in Dutch, literally "United
East Indies Company"). The VOC was the first multinational corporation in the
world as well as the first company to issue stock. In recent years, Dutch
foundations and holding companies have become increasingly popular due largely
to the country's accommodating tax laws.
Most notably, the Netherlands does not tax royalties. Accordingly, the country
has become a jurisdiction of choice for companies with international income
derived from intellectual property. Many of the world's largest multinational
corporations, including BHP Billiton, Coca-Cola, Nike, Ikea, Sun Microsystems,
and Gucci, have set up Dutch holding companies to take advantage of the
favorable tax environment.
Advantages of a Dutch Holding Company include:
 | No withholding tax on dividends in most cases |
| No capital gains on the sale of shares |
| Large tax treaty network |
| No withholding tax on EU dividends sent to the Dutch holding company |
| Ability to get a "ruling" from the Dutch tax authorities prior to forming complex international structures |
| No foreign currency exchange restrictions |
| Business-friendly commercial law |
| High degree of credibility due to strict laws designed to prevent abuse |
| Moderate costs |
In addition to the economic benefits described above, the Netherlands also
offers a stable political climate, international attitude, well-trained labor
force, and developed infrastructure including the world's second largest seaport
(Rotterdam) and a major aviation hub.
NOTE: Some countries, including the United States, have special
rules concerning royalties and passive income. Please consult tax counsel in
your country of domicile to ensure compliance with domestic regulations
