By Dubai Tax Resident Editorial Team · Last reviewed: October 2026
When you emigrate from the Netherlands, the Dutch tax authority issues a protective assessment (conserverende aanslag) on the unrealised gain in any substantial interest of 5% or more in a company, and on certain pension and annuity rights. You do not pay this tax immediately: it is collected if you later sell the shares, receive certain distributions or surrender pension rights. For people who emigrated after 15 September 2015, the assessment on a substantial interest no longer expires. After emigration, Box 3 wealth tax generally only applies to Dutch real estate.
Key facts
- Substantial interest: 5% or more of the shares of a company
- Exit mechanism: protective assessment on latent gains at Box 2 rates
- Box 2 rates: currently two brackets of 24.5% and 31%
- Collection: on sale, certain distributions, capital repayment or liquidation
- Expiry: no expiry for substantial interests after emigrations from 15 September 2015
- Pensions: protective assessment on pension and annuity rights, lapsing after 10 years
- Treaty: Netherlands-UAE tax treaty in force
How the Dutch exit tax works
The Netherlands does not charge an immediate cash exit tax for individuals. Instead, on the day you emigrate, it treats your substantial interest as sold and calculates the tax on the gain built up while you lived in the Netherlands. This amount is recorded in a protective assessment. The assessment stays open and becomes payable when a trigger event happens. Details are published by the Belastingdienst.
What triggers payment?
- selling or otherwise disposing of the shares,
- dividend distributions from the company, proportionally reducing the open assessment,
- repayment of capital or liquidation of the company, and
- transferring the shares, for example by gift.
For emigrations before 15 September 2015, the assessment expired after ten years. For later emigrations, it remains open indefinitely, which means a future sale of your company can still lead to Dutch tax on the gain built up before you left.
Pensions and annuities
Pension rights and annuities that received Dutch tax relief also receive a protective assessment on emigration. It becomes payable if you surrender, commute or otherwise breach the terms of the pension, and it lapses ten years after emigration. Regular pension payments in line with the scheme do not trigger it.
Box 3 after you leave
As a Dutch resident, you pay Box 3 tax on a deemed return on your savings and investments. After emigration, you become a non-resident taxpayer, and Box 3 generally only applies to Dutch real estate you still own, such as a rented-out apartment. The Box 3 system itself is being reformed towards taxation of actual returns, so check the current rules for the years you still own Dutch assets.
Inheritance and gift tax: the 10-year rule
Dutch nationals who emigrate are treated as Dutch residents for inheritance and gift tax for ten years after leaving. Gifts made or inheritances arising within that period can still be subject to Dutch tax, although treaties and unilateral relief may apply. Other nationals are treated as resident for one year after leaving for gift tax purposes.
Emigrating from the Netherlands to Dubai: steps
- Deregister from the municipal personal records database (BRP) when you leave.
- File the M-form (migration return) for the year of emigration, covering your resident and non-resident periods.
- Value your substantial interest as at the emigration date to support the protective assessment.
- Review pensions before emigrating to avoid triggering the pension assessment.
- Plan your company: if management stays in the Netherlands, the company itself can remain Dutch tax resident.
- Build your UAE residency, including a home and, once eligible, a UAE Tax Residency Certificate for treaty purposes.
For a comparison with other European countries, see our European exit tax guide.
Emigrating from the Netherlands with a company?
We help you understand the protective assessment, plan distributions and structure your move to Dubai.
Frequently asked questions
Yes, in the form of a protective assessment. When you emigrate, the Netherlands calculates tax on the latent gain in a substantial interest of 5% or more and on certain pension rights, and collects it later on trigger events.
A conserverende aanslag is a protective tax assessment issued on emigration. It records the Dutch tax on gains built up before you left, without immediate payment, and is collected if a trigger event such as a sale occurs.
For substantial interests, it no longer expires for people who emigrated after 15 September 2015. The protective assessment on pension and annuity rights lapses ten years after emigration.
Generally only on Dutch real estate you still own. Savings and foreign investments of a non-resident are outside Dutch Box 3.
Dutch nationals who emigrate remain treated as Dutch residents for inheritance and gift tax for ten years after leaving, so gifts and inheritances in that period can still be taxed in the Netherlands.
Yes. The Netherlands and the UAE have a double tax treaty, which can help resolve dual residence and allocate taxing rights after you emigrate.
The M-form is the Dutch migration tax return for the year you emigrate or immigrate. It covers both your resident and non-resident periods in that year.
Yes. Dividend distributions from a company in which you held a substantial interest can trigger partial collection of the protective assessment.
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Disclaimer: This article provides general information only and is not tax advice. Dutch emigration rules are detailed and change regularly; consult a qualified Dutch tax adviser before emigrating.
