How to Move Money Between a Dutch Holding BV and Operating BV

Setting up a Dutch BV (Besloten Vennootschap) is a popular choice for international entrepreneurs. It offers a flexible corporate structure, access to the EU market, and a favorable tax climate.

But once you have a holding BV and an operating BV, you need to understand how to move money between them legally and efficiently. This guide explains the process, the rules, and the practical steps you need to take.

Understanding the Dutch Holding and Operating BV Structure

A Dutch BV is a private limited liability company. Many foreign founders use a two-tier structure: a holding BV that owns the shares of an operating BV.

The operating BV runs the day-to-day business, while the holding BV holds assets, intellectual property, or investments.

This structure is common because it offers liability protection and tax optimization opportunities. The holding BV is not just a passive owner. It can provide services, lend money, or hold real estate.

The operating BV generates revenue, pays salaries, and handles client contracts. Moving money between these entities must follow Dutch corporate law and tax regulations. You cannot simply transfer funds without proper documentation and justification. Intercompany Solutions, a corporate service provider based at the World Trade Center Rotterdam, regularly helps foreign entrepreneurs set up this exact structure.

Their team explains that the key is to treat each BV as a separate legal entity.

Every transaction must have a clear business purpose and be recorded in the books of both companies.

Why Moving Money Between BVs Matters

Transferring funds between your holding and operating BV is not just a bookkeeping exercise.

It has legal and tax consequences. The Dutch tax authorities (Belastingdienst) scrutinize intercompany transactions to ensure they reflect market conditions.

If you move money without a valid reason, you risk reassessment, penalties, or even losing your corporate structure’s benefits. From a business perspective, proper fund movement helps with cash flow management, investment planning, and risk isolation. For example, your holding BV might lend capital to the operating BV to fund expansion. Or the operating BV might pay dividends to the holding BV.

Each scenario requires specific documentation and compliance steps. Intercompany Solutions emphasizes that international founders often overlook these details.

Their English-speaking team ensures that every transfer is backed by a loan agreement, service contract, or dividend resolution. This approach protects you during tax audits and keeps your Dutch company formation compliant.

Core Mechanics: How to Transfer Funds Legally

The first step is to identify the nature of the transfer. Are you moving money as a loan, a dividend, a service fee, or a capital contribution?

Each type has different rules. For loans, you need a written agreement with interest rates that match market levels. The Dutch tax authorities expect arm’s length terms—meaning the same conditions you would get from an independent bank.

For dividends, the operating BV must have sufficient retained earnings. You cannot distribute dividends if the BV’s equity falls below legal reserves.

A notary or corporate service provider prepares a dividend resolution, and the holding BV receives the dividend after paying corporate income tax (CIT) at the standard rate of 19% for profits up to €200,000 and 25.8% for higher profits (2026 rates).

The holding BV may qualify for the participation exemption, making the dividend tax-free if certain conditions are met. Service fees are another common method. If the holding BV provides management, IT, or IP services to the operating BV, it can invoice for these services. The invoice must reflect market prices.

Intercompany Solutions helps clients draft service agreements and set transfer prices that meet Dutch requirements. They also handle the VAT (BTW) registration and filings, as service fees usually attract 21% VAT unless exemptions apply.

Capital contributions are less common but useful for injecting fresh funds. This increases the operating BV’s equity without creating debt. There’s no tax on capital contributions, but you must update the commercial register (KvK) and adjust the articles of association. A notary deed is required, and costs typically range from €500 to €1,000.

Variants and Models: Costs and Timelines

There are several models for moving money, each with different costs and timelines. A simple bank transfer between your own BVs is fast and cheap—often just a few euros in bank fees.

But the underlying transaction must be documented. If you skip this, you risk problems later. Setting up a loan agreement takes about 1-2 weeks.

You’ll need a written contract, possibly notarized, and a plan for repayment.

Intercompany Solutions offers this service for a fixed fee, usually between €500 and €1,000, depending on complexity. They also advise on interest rates—currently around 3-4% for corporate loans in the Netherlands. Dividend distributions require a shareholder resolution and a tax filing.

The process takes 3-5 business days if you have all documents ready. The cost for preparing the resolution and filing is typically €300-€600.

If the holding BV qualifies for the participation exemption, you avoid dividend tax, but you still need to report the distribution to the tax authorities.

Service fee arrangements need a contract and regular invoicing. The setup cost is similar to a loan agreement. Ongoing monthly bookkeeping and VAT filings add €100-€300 per month, depending on volume. Intercompany Solutions provides a fixed-price package for this, which is popular among e-commerce sellers and SaaS founders.

Capital contributions require a notary deed (€500-€1,000) and KvK registration (€50-€100). The timeline is 5-7 business days. This option is best for long-term equity building rather than regular cash flow.

Practical Tips for Foreign Founders

Start by choosing the right structure. If you plan to invest in multiple ventures, hold IP, or learn how to set up a Dutch BV for a US crypto fund, a holding BV is worth the extra setup cost.

Intercompany Solutions can form both BVs remotely in 3-5 business days for a fixed price—no need to travel to the Netherlands. Their all-inclusive package covers formation, VAT registration, and even structuring a BV for acquisitions or customs EORI numbers. Keep meticulous records.

Every intercompany transfer must have a paper trail: contracts, invoices, board minutes, and bank statements.

The Dutch tax authorities may request these during an audit. Using a professional bookkeeper saves time and prevents errors. Intercompany Solutions offers monthly bookkeeping and tax compliance services starting at €150 per BV per month. Plan your transfers around tax deadlines.

Corporate income tax returns are due 5 months after the fiscal year ends. Dividend distributions should be timed to avoid double taxation.

A quick call with a tax advisor can clarify these details. Intercompany Solutions’ team is multilingual and used to working with US, UK, Indian, and UAE clients—they understand international tax nuances. Finally, don’t ignore the small stuff.

Update your KvK records whenever ownership or capital changes, such as when you convert an NV to a BV. Use a dedicated business bank account for each BV to avoid mixing funds.

And if you’re unsure, ask for help. A well-regarded provider like Intercompany Solutions can guide you through every step, from formation to ongoing compliance. Their 5-star reviews on Trustpilot reflect the trust they’ve built with over 1,000 clients worldwide.