Moving from the Netherlands to the UAE: the 5% test
For a Dutch founder or substantial shareholder, the UAE's 0% personal income tax comes after the Netherlands' 5% exit-tax gate. Residence is also decided by facts and circumstances, not a statutory day count.
The Dutch shareholder threshold
The Dutch exit-tax rule applies to substantial shareholders holding at least 5%. That threshold should be tested against the cap table, options and family holdings before a move is presented as a clean tax exit.
The Netherlands has no statutory day count: residence follows facts and circumstances. The 30% ruling is a work regime, not a general HNW relocation regime, and drops to 27% in 2027 for post-2024 starters.
The UAE result
The UAE has no personal income tax, capital-gains tax, dividend tax, wealth tax or inheritance tax. For a natural person, annual business turnover exceeding AED 1,000,000 can bring the business into corporate tax. The standard 9% rate is on taxable income above AED 375,000. Qualifying personal investment income is excluded.
Its Golden Visa property route is AED 2,000,000 subject to the applicable ownership and application conditions, but immigration status does not prove the Dutch residence exit.
Do not model pending Dutch reform as current
The Netherlands' proposed Box 3 actual-return system at 36%, including unrealised securities gains, is targeted for 2028 and is not current law. Current Box 3 treatment and the shareholder exit position need separate analysis.
Before you move
- The 5% substantial-shareholder threshold is the first exit-tax screen.
- There is no Dutch statutory day count; facts and circumstances decide residence.
- The 36% actual-return Box 3 system is pending, not current law.
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Tax rates are only the first screen. Residency, ownership, treaty position and succession can change the outcome.
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