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Dutch Companies as a Tax Planning Tool
St.Petersburg, September 28th 2010
Henk EikelboomJaap Bos
Why a company in the Netherlands?
The Netherlands have a:
- Good economic and financial climate - Political Stability- High level of Infrastructure- Multilingual majority of employees,- up to date educated and well informed
Key factors of The Netherlands
-Low jobless rate; low inflation and low interest rate;
-Good banking system
- Well organized system for monitoring and controlling financial markets and compliance through laws and regulations
Fiscal key factors (1)- Extensive tax treaty network with foreign countries (over 85!)
-Upfront negociation with the tax authorities is possible (rulings)
-Advantageous rules concerning intrests, dividends and royalty’s
Fiscal key factors (2)-Participation examption not only for dividends but also for currency gains an capitatal gains on shares(>5% ownership)
-No taxes on capital
-Carry back and carry over of losses
Witholding Tax for income from Dutch BV to a Russian companies
Dividend 5% (0% combination Dutch BV and Cyprus Ltd.)
Interest 0%
Royalties 0%
A Dutch B.V. (1)
- BV = private company with limited liability - Set up by a Notary (make up of the articles)
- Official permission of Ministery of Justice
- Minimum share capital is 18.000 euro
A Dutch B.V. (2)
- Registered in the Chamber of Commerce
- Located in The Netherlands for optimal tax advantages
- Director can be another company
Organigram
Russian company
Cyprus Ltd.
In any country
One or more BO’s
divi
dend
s
loan
s
inte
rest
s
Subsidiaries
Dutch B.V.
Russian company
Subsidiaries
Russian company
Dutch B.V.
Subsidiaries
Example loan
INTREST
Loan from Russian Comp. to subsidiaries
INTREST
INTREST
Witholding tax: 0%
Witholding tax: 0%
Witholding tax: 35%
Russian company
Subsidiaries (EU country without
treaty)
Russian company
Dutch B.V.
Subsidiaries (EU country)
Example dividendDividend from subsidiaries in Argentina to Russian holding
Witholding tax: 0%
Witholding tax: 0%
Witholding tax: 15%
Cyprus Ltd
Witholding tax: 0%
General remarks1. We don’t sell structures, we advise you what is the
best in your situation.
2. There are more possibilities by using f.e. Cyprus as a tax haven in combination with a Dutch B.V.
3. Think twice; tax playing is not a game.
What is Fundatio B.V.?1. A small trust office in Netherlands with licence of
the Dutch National Bank.
2. Member of a group of companies with tax advise, accounting and tax lawyers.
3. An international player with a network in Europe, East Africa and Curacao.
How can we serve you?1. We offer management and registered office for fix
prices;
2. We can advise you about international tax issues from The Netherlands;
3. We take care of your business in The Netherlands; one stop shopping issue
Fundatio B.V.Professional for professionals
Rondweg 11dP.O Box 59
8090 AA WEZEPThe Netherlands+31387370102
jaap.bos@fundatio .nl
