The Netherlands is a lovely place to leave: great airports, tidy forms and a tax authority with a web page for almost everything. The catch: the Dutch system follows you out the door with one very sticky tool, the conserving assessment (conserverende aanslag) on shares and pensions.
Below: when residency ends, how the exit tax works, what stays taxable, and what happens to the 30% ruling, AOW and your bank. General information as of September 2026, not tax advice.
Who this guide is for#
Dutch residents moving abroad, founders and DGAs (director-major shareholders) with a BV, expats on the 30% ruling heading to the next country, and anyone with a Dutch pension, annuity (lijfrente) or rental property. Leaving Germany instead? Read leaving Germany.
How Dutch residency ends#
The legal test: the circumstances#
Article 4 of the General Tax Act (AWR) is famously short: where someone lives is judged “naar de omstandigheden”, according to the circumstances. There’s no day count and no checklist in the law. Dutch courts look for a durable bond of a personal nature with the Netherlands.
In practice, the tax office weighs your home, where your partner and children live, where you work and invest, and where you’re registered, insured and see your doctor. No single fact decides. Keeping a furnished flat in Amsterdam while your partner stays behind is the classic way to stay Dutch in the eyes of the Belastingdienst, new Lisbon address or not.
The one-year fiction#
Article 2.2 of the Income Tax Act 2001 adds a trap for short trips: if you leave and come back to live in the Netherlands within one year, you’re treated as if you never left. The exception is when you can show you were tax resident in another EU country, a treaty country or the Caribbean Netherlands in the meantime. A gap year in no-tax land doesn’t count.
BRP deregistration: required, not decisive#
If you’ll live abroad for more than 8 months within one year, you must deregister from the Personal Records Database (BRP) as a resident. You report your departure to your municipality, in person no more than five days before you leave. Your data then moves to the non-residents register (RNI).
Deregistration is important evidence and triggers a lot of admin, but it doesn’t end tax residency on its own. If your life stays in the Netherlands, the certificate won’t save you.
Treaty tie-breaker#
If both the Netherlands and your new country claim you, the tax treaty decides using the tie-breaker in Article 4 of the OECD Model: permanent home, then centre of vital interests, then habitual abode, then nationality. No treaty means no tie-breaker. More on the tests in tax residency explained.
The M form for the year you leave#
For the year of emigration you file one return covering both parts of the year: as a resident until you leave, as a non-resident afterwards. You can do it online in Mijn Belastingdienst (the return for people who lived outside the Netherlands for part of the year) or on the paper M form. The conserving assessments below are part of this return.
Exit tax: the conserving assessment#
Substantial interest (box 2)#
You have a substantial interest (aanmerkelijk belang) if you, together with your fiscal partner, hold at least 5% of the shares in a company, Dutch or foreign. When you emigrate, the law treats you as if you sold those shares the moment you left: a fictitious disposal. The gain (market value minus your acquisition price) counts as box 2 income, and you receive a conserving assessment for the tax.
Box 2 rates for 2026 are 24.5% on the first €68,843 and 31% above that.
Now the part that surprises people:
- Deferral. You get deferral of payment without interest. When you move within the EU/EEA it’s automatic; for other countries, you usually have to provide security (a bank guarantee, mortgage or pledge).
- No expiry. If you deregistered before 15 September 2015 (15:15, to be precise), the old rules applied: ten years of deferral, then remission on request. Anyone who left after that gets lifelong deferral, and the assessment for a substantial interest is never written off.
- What ends the deferral. Selling the shares, the company stopping its business, and dividends. Each dividend paid after you left triggers collection of part of the assessment under Article 25(8) of the Collection Act 1990: roughly the box 2 rate on the dividend, minus Dutch dividend tax withheld and foreign tax actually paid on it.
That last rule matters a lot if you move to a zero-tax country. The Dutch dividend tax (15%) plus “top-up collection” can bring you close to the full box 2 rate on every distribution, forever.
Pensions, annuities and the own-home policy#
A conserving assessment is also imposed on the value of pension rights and annuities (lijfrente) built up with tax-deductible contributions, and on a capital insurance or savings account linked to your own home. The conserved income is taxed at the highest box 1 rate. These assessments generally run for 10 years: as long as you don’t surrender (afkopen) or otherwise breach the rules, you can ask for remission after 10 years. Surrender the pension or annuity within that window and the assessment becomes payable.
How it compares with Germany#
| Netherlands | Germany (§6 AStG) | |
|---|---|---|
| Threshold | 5% substantial interest | 1% holding |
| Residence requirement | None | 7 of the last 12 years |
| Payment | Deferred without interest (security outside EU/EEA) | 7 annual instalments, usually against security |
| Expiry | Never for box 2 (after 15 Sept 2015) | Can lapse if you return within 7 years (extendable) |
Full German detail in German exit tax explained.
Box 3 and your wealth after the move#
As a resident, box 3 taxes a deemed return on savings and investments: in 2026 at 36%, above a tax-free allowance of €59,357 per person, with a deemed 6.00% on investments and 1.28% on bank balances (provisional assessments). If your real return was lower, you can prove it under the counter-evidence scheme.
As a non-resident, box 3 shrinks to Dutch real estate (a rented-out flat, a holiday home), rights relating to it and certain profit-sharing rights in Dutch businesses. Dutch bank balances and investment accounts drop out.
The switch to a tax on actual returns, planned for 1 January 2028, passed the House of Representatives on 12 February 2026 but was still pending in the Senate as of September 2026. Keeping Dutch property? Watch this space.
The 30% ruling when you leave#
The expat ruling lets your employer pay up to 30% of salary tax-free for extraterritorial costs. In 2026 the minimum salary is €48,013 and the ruling covers salary up to €262,000. From 2027 the maximum drops to 27% for people who started in 2024 or later; those on the ruling at the end of 2023 keep 30% under transitional rules.
- It ends with your job. The ruling stops on the last day of the pay period after the period in which your last working day falls. Last day 15 February, monthly payroll: the ruling runs until 31 March.
- Partial non-resident status is gone. Since 1 January 2025 you can no longer opt to be treated as a non-resident for box 2 and box 3. Only people under the transitional rules (ruling applied in the last pay period of 2022 or 2023) can still use it, up to and including 31 December 2026.
What stays taxable after you leave#
Leaving ends your worldwide Dutch tax liability, not every link:
- Dutch employment. Work physically done in the Netherlands stays taxable there, subject to the treaty.
- Dutch real estate. Taxed in box 3 as described above.
- Substantial interest in a Dutch company. Dividends and sale gains can stay taxable in box 2, within treaty limits.
- Dividends on Dutch shares. Dutch companies withhold 15% dividend tax. A treaty may reduce it or give you a credit at home.
- Pensions and AOW. Whether the Netherlands or your new country taxes Dutch company pensions and AOW depends on the treaty. Read the pension article of the treaty with your destination.
If you live in another EU/EEA country or Switzerland and at least 90% of your worldwide income is taxed in the Netherlands, you can be a qualifying non-resident taxpayer and keep the same deductions and credits as residents.
Social security and health insurance#
AOW and voluntary insurance#
Each insured year builds 2% of your state pension, over the 50 years before your AOW age. Live or work abroad and you’re usually no longer insured: 2% less AOW per year. Voluntary insurance for AOW and/or Anw (survivors’ benefit) with the SVB fills the gap:
- You must have been insured for at least one full year right before you left.
- You apply within one year after you stop being insured.
- Voluntary insurance generally lasts up to 10 years, and it stops earlier when you reach AOW age or move back.
EU rules and treaties#
Within the EU/EEA and Switzerland, Regulation 883/2004 decides which country’s social security applies, usually where you work, and adds up insurance periods across member states. Bilateral agreements cover several other countries.
Health insurance#
Your Dutch basic health insurance (Zvw) generally ends when you emigrate. Cancel it after deregistering. Receiving a Dutch pension or benefit in a treaty country? You may register with the CAK and get care under local rules. Otherwise you need local or international cover.
Banks, brokers and DigiD#
- Tell your bank. Update your address and tax residency. Under the Common Reporting Standard (CRS), the bank then reports your accounts to your new country. Normal, not a problem.
- Expect questions. Some Dutch banks and brokers restrict services for customers outside the EU/EEA or in specific countries. Check the terms and open an account in your new country early. More in banking abroad.
- DigiD. You’ll need it for the Belastingdienst, SVB and pension funds. Activate the DigiD app with ID check and add a phone number before you leave; fixing it from abroad is slower.
Your exit, step by step
Map your Dutch footprint
List shareholdings of 5% or more, pensions and annuities, Dutch property, your 30% ruling status and where your income will come from after the move.
Value the company and plan the payout route
Get a defensible valuation of your BV. Decide how you will take money out later, because dividends trigger collection of the conserving assessment.
Build the facts abroad
Residence permit, long-term lease, local bank, health insurance and tax registration in your new country. Give up or rent out your Dutch home long-term.
Deregister and settle social security
Report your departure to the municipality (no more than five days before leaving), cancel your Zvw policy and decide on voluntary AOW/Anw insurance within one year.
File the M return
Report the year of emigration, including the conserving assessments. Keep your deregistration certificate and residence evidence.
Dutch exit traps
The one-year boomerang.
Move back within a year without tax residence in an EU or treaty country and you’re treated as if you never left.
The half-emigrated household.
Partner and kids stay in the Netherlands, you rent a flat in Dubai. The circumstances test will very likely put you in the Netherlands.
Dividends from Dubai.
Living in a zero-tax country makes every BV dividend trigger collection of the old box 2 bill on top of 15% dividend tax.
Surrendering the pension.
Cashing out a pension or annuity within 10 years makes the conserving assessment payable at the top box 1 rate.
Forgetting security.
Moving outside the EU/EEA without arranging security can mean no deferral of the exit tax.
Missing the AOW window.
One year after you stop being insured, voluntary insurance is off the table.
Worked example: a DGA moves to Dubai#
Illustrative numbers only, using 2026 box 2 rates. Sanne owns 100% of her BV. She paid in €20,000; the BV is worth €1,200,000 when she moves to the UAE in 2026 and deregisters.
| Item | Amount |
|---|---|
| Market value of shares at emigration | €1,200,000 |
| Acquisition price | €20,000 |
| Fictitious gain (box 2) | €1,180,000 |
| Tax: 24.5% on €68,843 + 31% on the rest | ≈ €361,000 |
| Payment | Deferred for life, security needed outside the EU/EEA |
Three years later the BV pays her a €200,000 dividend:
| Item | Amount |
|---|---|
| Dutch dividend tax withheld (15%) | €30,000 |
| Box 2 rate on the dividend (31%) | €62,000 |
| Minus dividend tax and UAE tax (none) | €62,000 − €30,000 − €0 |
| Part of the conserving assessment collected | €32,000 |
Total Dutch take on that dividend: about €62,000, or 31%. Foreign tax on the dividend would reduce the collection, so Cyprus, Malta or Portugal change the maths in different ways. Model the payout, not just the headline rate.
Leaving the Netherlands: the 12-month plan
Tick them off – your progress is saved in this browser only.
List substantial interests, pensions, annuities, Dutch property and your 30% ruling end date. This is when restructuring is still possible.
Compare tax, treaty, residency rules and life with our Jurisdiction Finder and the country guides.
If you keep a BV, decide who manages it and from where (place of management). Get a valuation of your shares.
Apply for your residence permit, sign a long-term lease, open a local bank account, price health insurance and ask the SVB about voluntary AOW/Anw insurance.
Give notice on your rental or arrange a long-term letting. Prepare security if you move outside the EU/EEA.
Report your departure to the municipality (at most five days before leaving). Keep the proof. Cancel your Zvw policy.
Tell banks, brokers, pension funds and the Belastingdienst your new address and tax residency. Register with the tax office in your new country. Track your days with the day tracker.
File the return for the year of emigration, including the conserving assessments.
FAQ#
Does deregistering from the BRP end my Dutch tax residency?
No. Residency is judged on all circumstances under Article 4 AWR. Deregistration is strong evidence, but a home, partner or business left behind can keep you resident.
Does the Dutch exit tax on shares ever expire?
For a substantial interest, no, if you deregistered after 15 September 2015. You get lifelong deferral, but the assessment stays and is collected on a sale or partly on dividends. Pension and annuity assessments can be remitted after 10 years.
What happens to my 30% ruling when I leave?
It ends on the last day of the pay period after the one in which your last working day falls. It doesn’t travel with you.
Can I keep building AOW while living abroad?
Yes, through voluntary insurance with the SVB, if you were insured for at least a year before leaving and apply within one year. It generally runs for up to 10 years.
Do I still pay box 3 on my Dutch savings as a non-resident?
No. Non-residents only pay box 3 on Dutch real estate, related rights and certain profit-sharing rights. Dutch bank balances and investments drop out.
Everything here is general information, not tax or legal advice. Applying these rules to a BV, a pension and a family is where a second pair of eyes pays off. Want your exit plan checked before you go? Book a strategy session.
Sources#
- Art. 4 Algemene wet inzake rijksbelastingen (AWR) – residence by circumstances
- Wet inkomstenbelasting 2001 – incl. art. 2.2 (one-year fiction) and box 2
- Government.nl – when to deregister from the BRP
- Belastingdienst – filing a tax return for the year of emigration (M)
- Belastingdienst – emigration checklist
- Belastingdienst – conserving assessment on emigration
- Belastingdienst – te conserveren inkomen 2026
- Belastingdienst Kennisgroepen – KG:207:2025:1, dividends and deferral (art. 25(8) Invorderingswet 1990)
- Belastingdienst – box 2 rates
- Belastingdienst – box 3 calculation 2026
- Rijksoverheid – box 3 and the counter-evidence scheme
- Eerste Kamer – Wet werkelijk rendement box 3 (36.748)
- Belastingdienst – living abroad with Dutch income
- Belastingdienst – qualifying non-resident taxpayer
- Belastingdienst – dividend tax
- Rijksoverheid – expat ruling (30% ruling) 2026–2027
- Belastingdienst – validity and end of the 30% ruling
- Belastingdienst – partial non-resident status
- SVB – how AOW is built up
- SVB – conditions for voluntary insurance
- SVB – duration of voluntary insurance
- Rijksoverheid – health insurance when living abroad
- Regulation (EC) No 883/2004 – coordination of social security systems
- OECD Model Tax Convention on Income and on Capital (2017)
