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Resident and non-Resident tax liabilities

Entities established in the Netherlands are resident taxpayers. Foreign taxpayers are entities that receive income from the Netherlands, but are established abroad.

Whether a company is established for tax purposes in the Netherlands depends on:


  • the place where the management is located

  • the location of the headquarters

  • the place where the shareholders' meeting takes place

  • Bodies incorporated under Dutch law are established in the Netherlands according to the Corporate Income Tax Act.


Domestic taxpayers are involved in the levy for their worldwide profit. The Dutch tax law does not contain any delimitation as to the territorial origin of the profit. This is in contrast to foreign taxpayer bodies that are only included in the levy for their Dutch income, the components of which are exhaustively listed in Chapter III of the VPB Act 1969 ( art. 17-19 VPB Act 1969. This difference in the subject of taxation between domestic and foreign tax obligations can be traced back to generally accepted principles of international tax law under which a state defines its tax sovereignty, namely the so-called residence principle (for resident taxpayers) and the so-called source principle (for foreign taxpayers).

Enjoying Dutch income is a precondition for the existence of a foreign tax liability. The so-called source country principle applies here. Chapter III of the VPB 1969 Act ( Articles 17 - 19 ) is devoted to Dutch income . The most important part of the Dutch income is the profit from a company that operates in the Netherlands with the help of a permanent establishment located in the Netherlands. This also includes any source of income originating from real estate located in the Netherlands.


Domestic tax payers, local Dutch companies, automatically receive a corporate income tax number. Foreign taxpayer, who for example have purchased real estate in the Netherlands and are receiving income, can apply for a corporate tax number voluntarily. However this is not always necessary. Foreign taxpayers can submit a corporate tax return, by filing a hard copy form.


You can contact the Tax Hotline for global entrepreneurs at +31 555 385 385 to request the form. House of Companies will shortly upload the tutorial on how to submit your corporate tax return as foreign tax payer.


If you registered a Dutch company, or your company is considered a resident taxpayer, you will receive an invitation (and tax number!) automatically from the DUtch Tax 7 Customs Administration.

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10 Chapters on Company Formation in the Netherlands

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