Compare · Benelux

Belgium, the Netherlands or Luxembourg: which holding fits your group?

Three neighbours, three of Europe's most used holding countries. All exempt dividends and exit gains and have full access to the EU directives. They differ on thresholds, tax and what each does best. Answer four questions and see which one fits.

Belgium

Corporate tax25%
Exemption10% or EUR 2.5m, 1 year
TreatiesAbout 95

Netherlands

Corporate tax19% / 25.8%
Exemption5%, no holding period
TreatiesAbout 100

Luxembourg

Corporate tax23.87%
Exemption10% or EUR 1.2m, 1 year
Treaties88
Benelux picker

Which of the three fits your case?

Four questions. The scores and reasons update as you click.

1. What will the holding do?

2. Your stakes

3. Who owns the holding?

4. What matters most after tax?

A first orientation, not tax advice. We set up companies in Luxembourg, the Netherlands and Belgium, and tell you on the call which one fits.

Head to head

The three compared

All three clear the same bar. The question is not which is best, but best for what.

BelgiumNetherlandsLuxembourg
Holding companySA or SRLB.V.SOPARFI (S.à r.l. or S.A.)
Minimum capitalNone for an SRL (financial plan needed)EUR 0.01EUR 12,000 (S.à r.l.)
Participation regimeDividends-received deductionParticipation exemptionParticipation exemption
Threshold10% or EUR 2.5m, held 1 year5%, no holding period10% or EUR 1.2m (EUR 6m for gains), 1 year
Dividends and gainsExempt, under conditionsExemptExempt
Corporate tax25%19% / 25.8%23.87% (Luxembourg City; 22.80% planned for 2027)
Net wealth taxNoneNoneMinimum from EUR 535
Tax treatiesAbout 95About 10088
Best known forFinancing and innovation regimesCorporate groups, low thresholdFunds and investment vehicles
Where each one wins

Three strengths, three use cases

Belgium

For financing and innovation

Groups with treasury, financing or IP activity that benefit from Belgium's innovation income deduction, or with operations in Belgium.

We will tell you if it is the better answer.
Netherlands

For corporate groups

The default for operating groups: 5% threshold, no holding period, about 100 treaties, no net wealth tax.

See the Netherlands holding →
Luxembourg

For funds and investors

SCSp, RAIF, SIF and SICAR for private equity and multi-investor platforms, and clean exits by liquidation.

See the Luxembourg holding →
The common condition

Substance applies in all three

All three apply the OECD BEPS standards and the EU anti-avoidance rules. The exemption, treaty rates and directives depend on real management and on passing the principal purpose test, whichever country you choose.

The country choice optimises the structure. It never removes the need for a real function.

FAQ

Benelux questions

Is Belgium a good holding country?+

Yes, for the right group. The dividends-received deduction exempts qualifying dividends in full, and the innovation income deduction helps IP-heavy groups. For pure holdings, the Netherlands and Luxembourg are usually simpler.

Do you set up Belgian companies?+

Yes. We set up Belgian SRLs and SAs remotely: financial plan, notary, enterprise number, VAT and UBO filing. See company formation in Belgium.

Which has the lowest threshold?+

The Netherlands: 5% with no holding period. Belgium and Luxembourg need 10% or a minimum investment, held for a year.

Which is best for a fund?+

Luxembourg, by a distance: SCSp, RAIF, SIF and SICAR are what international investors expect.

Which is cheapest to run?+

The Netherlands usually: minimal capital and no net wealth tax. Luxembourg adds a minimum net wealth tax; Belgium has more reporting.

Case law in English

What the courts decided

Our reviews of the leading judgments on these rules, with every provision linked to the English text.