Hi everyone,
I hold a substantial amount of wealth in Bitcoin. For those unfamiliar with the Dutch tax system, if you keep your wealth private, you're subject to an annual wealth tax of approximately 2.25% of your net worth.
I earn a good salary, but not enough to cover this wealth tax without selling my Bitcoin. Furthermore, from 2028, there is a strong possibility that unrealized gains will be taxed based on actual returns, making the wealth tax even more unfavourable.
Has anyone living in the Netherlands explored structures that could achieve a more tax-neutral position?
No annual wealth tax
To access funds, Bitcoin must be sold within the BV, incurring capital gains tax, and distributed as dividends—resulting in a total effective tax rate of ~37-38%
While I could avoid dividend tax by loaning funds to myself from the BV, capital gains tax on Bitcoin sales would still apply
Ongoing costs of maintaining the structure (likely lower than the wealth tax but still a consideration)
Exit tax—if I leave the Netherlands in 5-15 years and try to "cash out" in a lower-tax jurisdiction, an exit tax applies if I transfer unrealized profits or move the company abroad
No annual wealth tax
Potentially no capital gains tax, as the foreign company would be located in a low/no-tax jurisdiction
No exit tax? Since the Bitcoin is held in the Curaçao entity from day one, closing the Dutch Holding BV upon leaving the Netherlands would not trigger exit tax, as the Bitcoin remains outside the Dutch tax system
Same issue as Option 1—either pay dividend tax or structure a loan from the foreign company
Higher costs—would need to pay for a nominee director in Curaçao to separate myself from the company, plus additional administrative costs (annual reports, compliance, etc.)
Would love to hear from anyone who has considered or implemented similar structures. Are my assumption incorrect? Any insights, experiences, or alternative strategies would be greatly appreciated!
I hold a substantial amount of wealth in Bitcoin. For those unfamiliar with the Dutch tax system, if you keep your wealth private, you're subject to an annual wealth tax of approximately 2.25% of your net worth.
I earn a good salary, but not enough to cover this wealth tax without selling my Bitcoin. Furthermore, from 2028, there is a strong possibility that unrealized gains will be taxed based on actual returns, making the wealth tax even more unfavourable.
Has anyone living in the Netherlands explored structures that could achieve a more tax-neutral position?
Option 1: Holding BV + Investment BV
This structure involves setting up a Holding BV that owns shares in an Operating BV (classified as an Investment BV). The Operating BV would hold Bitcoin, injected as starting capital.Pros:
No annual wealth taxCons:
To access funds, Bitcoin must be sold within the BV, incurring capital gains tax, and distributed as dividends—resulting in a total effective tax rate of ~37-38% While I could avoid dividend tax by loaning funds to myself from the BV, capital gains tax on Bitcoin sales would still apply Ongoing costs of maintaining the structure (likely lower than the wealth tax but still a consideration) Exit tax—if I leave the Netherlands in 5-15 years and try to "cash out" in a lower-tax jurisdiction, an exit tax applies if I transfer unrealized profits or move the company abroadOption 2: Holding BV (NL) + Foreign Company (e.g., Curaçao)
In this setup, a Holding BV in the Netherlands owns shares in a foreign company (e.g., Curaçao), where the Bitcoin is held.Pros:
No annual wealth tax Potentially no capital gains tax, as the foreign company would be located in a low/no-tax jurisdiction No exit tax? Since the Bitcoin is held in the Curaçao entity from day one, closing the Dutch Holding BV upon leaving the Netherlands would not trigger exit tax, as the Bitcoin remains outside the Dutch tax systemCons:
Same issue as Option 1—either pay dividend tax or structure a loan from the foreign company Higher costs—would need to pay for a nominee director in Curaçao to separate myself from the company, plus additional administrative costs (annual reports, compliance, etc.)Would love to hear from anyone who has considered or implemented similar structures. Are my assumption incorrect? Any insights, experiences, or alternative strategies would be greatly appreciated!
