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How to structure your wealth via Dutch and Hungarian structures

Monday, 09 January 2017

Real Estate opportunities

  • Budapest Performed as the Best in CEE in Most Key Hotel Performance Indicators in Q1 2015
  • Compared with other countries, the yields that can be attained on the Hungarian commercial real estate market are quite attractive.
  • For example, prime office yields were around 7.5 % at the end of 2014. The prime yields for the best shopping centres were around 7% and slightly below 9% for the logistics sector

DBH Trust Services

  • DBH recently acquired a Mid Size Trust company
  • Independent
  • We speak your language: English, Russian, French, German, Ukrainian, Dutch, Spanish, Chinese.
  • Management team of 3 partners
  • Fully licensed by Dutch Central Bank
  • Office at 3 locations in The Netherlands

( Maastricht, Eindhoven and Amsterdam )

Benefits from The Netherlands

  • Participation exemption
  • Strong and stable tax treaty network
  • No or decreased withholding tax on dividends
  • No withholding tax on interest and royalties
  • Advance tax rulings with tax authorities ( Free and Quick )
  • Outstanding financial service industry
  • Leading Banks ( ING, ABN AMRO, Rabobank )

Dutch Participation Exemption (PE) Regime

  • Companies which are tax resident in NL are generally subject to Dutch corporate income tax at the regular corporate income tax rate of 20-25%
  • A Dutch company is taxed for its worldwide profits (including business, trading, dividend, royalty and interest income)
  • Under the PE Regime certain income items received in connection with a qualifying shareholding are exempt from Dutch corporate income tax
  • These income items include dividends, other profit distributions, capital gains and foreign exchange rate results realized by a Dutch resident company. Fiscal substance in the Netherlands is essential!

Structuring a (real estate and VC ) fund through the Netherlands

  • The overall Legal/Tax/Regulatory/Accounting infrastructure is favorable for structuring a fund in or through the Netherlands
  • Legal: BV (Dutch private limited) and CV (private partnership)
  • Rules applicable to BVs have been considerably relaxed recently (e.g. no capital requirement)
  • Tax: participation exemption and transparent tax structure, possibility to implement tax neutral structures
  • Advanced tax ruling

The Netherlands: a trust hub

  • Substance is essential for the application of the PE regime
  • Dutch trust companies help their international clients in providing (fiscal) substance though providing management and domicile
  • Dutch trust firms also help clients in the setting up of a Dutch company and coordinate professional services (legal, tax, auditing and banking services).
  • Trust companies get their license from the Dutch Central Bank and operate under strict supervision 

Trust in The Netherlands


  • The management, domiciliation and administration of Dutch companies on behalf of others (based on “trust”)
  • Primarily used for corporate tax planning for holding, finance, royalty or real estate activities

Is not:

the legal instrument of a Trust mainly used in

Anglo-Saxon jurisdictions for:

– asset protection or creation of family / charity funds

– saving inheritance tax (income tax on interest income)

– located often in off shore jurisdictions 

You may create a presence in the Netherlands to secure benefits sought under treaties for the avoidance of double taxation.

How to create Substance

  • Domicile in the Netherlands
  • Majority of Dutch directors
  • Professional knowledge
  • Decisions taken in the Netherlands
  • Bank account in the Netherlands
  • Administration and annual accounts prepared in the Netherlands


  • There are high potentials in investing in European tech companies, especially in Central Europe (arbitrage) e.g. Hungary
  • Hungarian (Budapest) real estates are undervalued thus there are great opportunities
  • Dutch and Hungarian structures are favorable to organize investments in Europe.


  • Phone: +44 203 519 34 84


  • Phone: +3 572 200 86 84


  • Phone: +38 044 501 78 87


  • Phone: +7 727 350 54 74


  • Phone: +7 499 705 91 98



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