Smaller flows do not remove the need to explain structure, timing, payments, and tax records.
A founder with a Dutch BV, a foreign shareholder, and one intra-group loan may sit far from the tax-avoidance debate. On the desk, the work is ordinary: invoices, board decisions, a dividend plan, a return, maybe a foreign subsidiary that never really took off. Yet national tax policy reaches that table through governance, timing, and proof.
The economic route comes first
In June 2026, Finance Ministry decision notes for a written parliamentary exchange on tax avoidance set the frame, tied to documents including Kamerstuk 25087-357. DNB figures published on 23 April 2026 add the market picture. This is not one note. It is a pattern of measurement.
The numbers are now concrete. The Finance Ministry reported that outgoing income flows from the Netherlands to low-tax jurisdictions fell from €37.1 billion in 2019 to €6.5 billion in 2024. DNB reported that financial holdings of multinationals in the Dutch doorstroom sector fell from more than 14,000 in 2017 to fewer than 8,000 in 2025. Active Dutch trust offices roughly halved over the same period.
The shrinking route is not the whole story
DNB describes doorstroom as a Dutch subsidiary receiving funds from a foreign parent and passing them abroad, instead of using the money for Dutch business operations. That matters because it separates an ordinary operating company from a balance-sheet route with little staff, few local operations, and large foreign assets and liabilities.
Legal form is not the whole story
For a baker, installer, local shop, design studio, or ZZP worker without foreign structures, these figures do not change the business model. The pressure arrives when cross-border ownership, payments, loans, royalties, dividends, or a foreign exit enters the file.
The official monitoring letter also sharpens the tax picture. The source withholding tax on interest and royalties is judged effective. The dividend measure has not yet shown a clear visible effect. In 2024, the remaining low-tax flow still stood at €5.2 billion, mainly dividends and retained earnings. DNB flow data and Belastingdienst return data are read together, but they are not the same instrument.
Where a small company can feel the pressure
Return to the founder at the table. The BV has real clients, staff, rent, and bank movements. It is not an empty shell. Still, a foreign shareholder asks for a dividend, a related company charges a management fee, or a loan sits between two group companies. At that moment, the question is no longer only whether the structure is allowed.
The better question is whether the business can explain itself without drama. Why was the payment made? Who decided it? Which contract supports it? How was the price set? Where is the invoice, the bank proof, the board minute, the tax treatment, and the bridge to the annual accounts? Good governance often looks dull because it prevents excitement later.
This is also why split realities are dangerous. The adviser has one story, the bank another, the accountant a third, and the director keeps the commercial reason in memory. That is fragile. When tax, banking, audit, or sale questions arrive, memory is a poor archive.
Court timing can move cash
The liquidation-loss issue shows why dates matter. In ECLI:NL:HR:2025:417, the Hoge Raad ruled on 21 March 2025 in a corporate income tax case concerning article 13d of the Wet op de vennootschapsbelasting 1969 and a liquidation loss of more than €202 million. The court held that the non-relief condition had to be tested when the liquidation was completed. The taxpayer succeeded.
Follow one revenue stream
That ruling did not stay inside the courtroom. A Finance Ministry decisnota estimated an incidental budgetary loss of €840 million and a structural loss of €65 million per year. The cabinet proposed covering that loss through a change in the fiscal treatment of priced-in currency results under the participation exemption, with an intended route from 2027. One timing point became a budget, treasury, and accounting question.
Commercial and taxable profit are not twins
A Finance Ministry study linked corporate income tax data for 2010 to 2020 with CBS data on commercial annual accounts for large enterprise groups. For the companies studied, the taxable amount was on average €29 billion lower than commercial profit. Much of that difference came from the participation exemption and loss relief, with depreciation and revaluations also playing a role.
That gap is not automatically avoidance. It is a bridge that must be understood. For a small group with a holding, participation, foreign subsidiary, or old loss position, the practical issue is similar in miniature. Commercial profit and taxable profit may differ for valid reasons. The director still needs to know those reasons before a lender, buyer, adviser, or inspector asks.
Quiet discipline beats tax panic
The trailing-tax research after emigration is a useful check against slogans. The expected fiscal interest was limited, about €16 million to €38 million depending on the variant. The study also pointed to behavioural effects, execution costs, privacy sensitivity, foreign information problems, and treaty conflicts in almost 90 percent of studied cases. Residence is evidence, not a headline.
Belastingdienst confidentiality rules complete the picture. Private and business tax data are protected, and public policy documents do not open individual taxpayer files. That means the company must carry its own explanation. A founder cannot rely on the state, the bank, the accountant, or the memory of a former adviser to reconstruct the story later.
The Dutch tax-avoidance debate has become more measured and less theatrical. Some routes have clearly contracted. Some questions remain open, especially around dividends and retained earnings. For micro and small business owners, the practical conclusion is simple: if the company has cross-border features, keep structure, payments, dates, accounts, and decisions readable to the people who may one day trust them.
Sources
- Rijksoverheid, Ministerie van Financiën – Annual monitoring of anti-tax-avoidance measures
- De Nederlandsche Bank – Doorstroom sector contraction
- De Nederlandsche Bank – Definition and mechanics of doorstroom
- Rechtspraak – Supreme Court ruling on the liquidation loss regime
- Rijksoverheid, Ministerie van Financiën – Budgetary and policy response to the liquidation loss ruling
- Rijksoverheid, Ministerie van Financiën – Fiscal treatment of currency hedging under the participation exemption
- Rijksoverheid, Ministerie van Financiën – Trailing tax after emigration
- Rijksoverheid, Ministerie van Financiën – Commercial profit versus taxable amount
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