Exit Tax in the Netherlands: What to Know Before Moving to Bulgaria

Q: Is Box 3 wealth tax affected when I emigrate?

Yes, but favorably. Once you are no longer a Dutch tax resident, you are no longer subject to Box 3 wealth tax on your worldwide savings and investments. Box 3 tax ends on the date of your emigration. In 2026, the Box 3 effective rate is approximately 2.80% (36% tax on a 7.78% deemed return), so leaving can save significant amounts for those with substantial investment portfolios.

Why Dutch Entrepreneurs Are Looking at Bulgaria

The Netherlands has long been a popular base for international entrepreneurs. But between rising Box 2 rates, the Box 3 wealth tax overhaul, the shrinking 30% ruling, and one of the EU's highest overall tax burdens, a growing number of Dutch business owners are exploring relocation — and Bulgaria keeps coming up.

The appeal is obvious: Bulgaria's combined corporate income tax and dividend tax is just 15% (10% CIT + 5% dividend tax). That compares to an effective rate of roughly 40-45% in the Netherlands for a BV owner distributing profits through Box 2. Bulgaria joined the Schengen area on January 1, 2025, and adopted the euro on January 1, 2026 — removing the last practical barriers for Dutch entrepreneurs.

But leaving the Netherlands is not as simple as booking a flight to Sofia. The conserverende aanslag (preserving tax assessment) can create a significant paper tax liability on departure. This guide explains exactly how it works, what it means for your move, and how to plan around it.

24.5–31%

Dutch Box 2 tax rate (2026)

15%

Bulgaria combined CIT + dividend

Bulgaria exit tax

2022

NL-BG new treaty in force

What Is the Dutch Exit Tax (Conserverende Aanslag)?

The conserverende aanslag is the Netherlands' version of the EU-mandated exit tax. When you emigrate from the Netherlands while holding a substantial interest (aanmerkelijk belang) in a company, the Dutch tax authority (Belastingdienst) issues a preserving tax assessment.

In practical terms, the Belastingdienst treats your shares as if you sold them on the day you deregistered from the Netherlands. The difference between the fair market value and your original acquisition cost becomes a deemed capital gain, taxed at Box 2 rates.

This is not an additional tax. It is the same Box 2 tax you would pay if you actually sold the shares — it is simply triggered by your departure instead of by a sale. The key difference is that you do not actually receive any money from this "sale," yet you have a tax liability on paper.

Key point: The conserverende aanslag is assessed but not immediately collected when you move to another EU/EEA country. For moves to Bulgaria, payment is automatically deferred until you actually dispose of the shares.

Who Is Affected: Aanmerkelijk Belang (Substantial Interest)

The Dutch exit tax applies specifically to holders of an aanmerkelijk belang — a substantial interest. You have a substantial interest if you (alone or together with your fiscal partner) hold:

5% or more of the total shares in a company (BV, NV, or foreign equivalent)
5% or more of the profit-sharing rights
5% or more of the voting rights (in a cooperative)
Options that, if exercised, would give you 5% or more

This means virtually every DGA (directeur-grootaandeelhouder) — the owner-director of a Dutch BV — is subject to the conserverende aanslag upon emigration. If you own 100% of your BV and leave the Netherlands, the full unrealized gain on your shares triggers the assessment.

What about shares below 5%?

Shares below the 5% threshold fall under Box 3, not Box 2. Box 3 has its own emigration consequences (covered below), but they are less dramatic because Box 3 is a wealth tax on deemed returns, not a capital gains tax on actual appreciation.

How the Exit Tax Works: Step by Step

Here is the mechanical process when a BV owner emigrates from the Netherlands:

Deregister from BRP: You must deregister from your municipality (gemeente) between 5 days before and the day of departure. This formally ends your Dutch residency.
File the M-biljet: For the year of emigration, you file a special tax return called the M-biljet (M-form). This form combines a resident return (for the period you lived in NL) and a non-resident return (for the remainder of the year).
Valuation: The Belastingdienst determines the fair market value (waarde in het economisch verkeer) of your substantial interest on the date of emigration.
Assessment: A conserverende aanslag is issued for the deemed gain. For 2026, Box 2 rates are 24.5% on the first EUR 68,843 and 31% on the excess.
Automatic deferral: Since Bulgaria is an EU member state, payment is deferred automatically. No security deposit is required for intra-EU moves.

Example: You own 100% of a Dutch BV valued at EUR 500,000. Your original share capital was EUR 18,000. Deemed gain: EUR 482,000. Tax at Box 2 rates: EUR 68,843 x 24.5% = EUR 16,866 + (EUR 413,157 x 31%) = EUR 128,079. Total conserverende aanslag: approximately EUR 144,945. This amount is assessed but deferred — you pay nothing upfront.

EU Deferral Rules: Why Bulgaria Moves Are Favorable

Under the Anti-Tax Avoidance Directive (ATAD) Article 5, EU member states must allow deferral of exit tax for moves within the EU/EEA. The Netherlands implements this generously for substantial interest holders:

Automatic deferral: No application needed. The deferral is granted by default for moves to EU/EEA countries.
No security required: Unlike Germany (which demands bank guarantees), the Netherlands does not require security for intra-EU deferrals on substantial interest.
Indefinite duration: The conserverende aanslag for substantial interest has no expiry date. Other types of conserverende aanslagen expire after 10 years, but the AB-claim (aanmerkelijk belang claim) remains indefinitely — until you actually sell the shares.
Annual reporting: You must file an annual declaration (conserverende aangifte) confirming you still hold the shares. Failure to file can trigger immediate collection.

Practical impact: If you move to Bulgaria and never sell your Dutch BV shares, the conserverende aanslag is never collected. If you liquidate the BV from Bulgaria, the treaty determines which country taxes the gain. Many entrepreneurs structure their exit by first establishing a Bulgarian company and gradually shifting operations, avoiding the need to sell the Dutch BV shares at all.

Box 3 Considerations: Wealth Tax and Emigration

If you hold investments outside your BV — savings accounts, stock portfolios, real estate funds — these fall under Box 3. The wealth tax implications of leaving the Netherlands are significant:

2026 Box 3 rate: 36% tax on a deemed return of 7.78% for "other assets" (overige bezittingen), creating an effective wealth tax of approximately 2.80% per year
On emigration: Box 3 liability ends on the date you leave. You pay Box 3 tax proportionally for the period you were a Dutch resident that year
No exit tax on Box 3 assets: There is no conserverende aanslag for Box 3 assets (unless you held the partial foreign tax liability status, in which case certain Box 3 assets may come into play)
Bulgaria equivalent: Bulgaria has no wealth tax. Investment income is taxed at 10% flat only when realized (dividends, interest, capital gains). This is a major savings for anyone with a significant investment portfolio

For someone with EUR 500,000 in investments, the Dutch Box 3 tax is approximately EUR 14,000 per year. In Bulgaria, the same portfolio generates zero tax until you sell or receive dividends — and even then, it is just 10% on the actual gain.

The 30% Ruling: What Happens When You Leave

If you are (or were) a 30% ruling holder, your departure has specific consequences:

Ruling ends immediately: The 30% ruling terminates on the day you leave the Netherlands. There is no grace period.
Partial foreign tax liability gone: Since January 1, 2025, new 30% ruling holders can no longer opt for partial foreign tax liability (partieel buitenlands belastingplichtige). This option previously allowed you to be treated as a non-resident for Box 2 and Box 3 purposes, even while living in the Netherlands.
Transitional rules: If you had the 30% ruling in the last pay period of 2023, you can still use partial foreign tax liability through the end of 2026. After that, it ends for everyone.
Salary cap (2026): The ruling applies to a maximum salary of EUR 262,000. The first 30% (up to EUR 78,600) is tax-free. Any salary above EUR 262,000 is fully taxable.
No clawback: There is no requirement to repay 30% ruling benefits if you leave. However, if you had the ruling for less than the full period, you simply stop receiving the benefit.

For 30% ruling holders considering Bulgaria: The end of partial foreign tax liability makes staying in the Netherlands less attractive for those with significant Box 2 or Box 3 assets. If your ruling is ending anyway, the timing may be right to evaluate a Bulgaria move — where corporate profits are taxed at 10% and dividends at 5%, for a combined rate of just 15%.

The Netherlands-Bulgaria Double Tax Treaty

A new double tax treaty between the Netherlands and Bulgaria entered into force on July 31, 2021 and applies from January 1, 2022. This modern treaty replaces the older agreement and is critical for anyone planning a move between the two countries.

Key treaty provisions

Dividends: Withholding tax on dividends is capped at 15% (general rate). Reduced to 5% if the beneficial owner is a company holding at least 10% of the paying company's capital. Exempt if held for 365+ days with 10%+ participation (parent-subsidiary).
Interest: 5% withholding tax, with exemptions for banks and government entities.
Capital gains on shares: The treaty allows the Netherlands to tax capital gains on shares in Dutch companies, including through the conserverende aanslag mechanism. However, Bulgaria can also tax gains on shares in Bulgarian companies.
Real estate clause: Gains from shares in companies deriving more than 50% of their value from immovable property can be taxed in the country where the property is located.
Principal purpose test: The new treaty includes a principal purpose test (PPT) that can deny treaty benefits if one of the main purposes of an arrangement is to obtain a tax advantage.

How the treaty affects your exit tax

When you eventually sell shares that were subject to the conserverende aanslag, the treaty prevents double taxation. The Netherlands retains the right to tax the gain accumulated before your departure. Bulgaria taxes any gain accumulated after you became a Bulgarian tax resident. Credit mechanisms ensure you do not pay tax twice on the same gain.

Tax Comparison: Netherlands vs Bulgaria

Tax Category	Netherlands (2026)	Bulgaria (2026)
Corporate income tax	19% (up to EUR 200K) / 25.8% (above)	10% flat
Dividend tax	24.5% (first EUR 68,843) / 31% (above) — Box 2	5% flat
Combined CIT + dividend	~39-45% effective	15% (10% + 5%)
Wealth tax (Box 3)	~2.80% effective per year	None
Personal income tax	36.97% / 49.50% (Box 1)	10% flat
Exit tax	24.5-31% (conserverende aanslag)	None
VAT standard rate	21%	20%
Capital gains (actual sale)	Box 2: 24.5-31%	10% flat
Currency	EUR	EUR (since Jan 1, 2026)

Real numbers: A BV earning EUR 200,000 in profit pays EUR 38,000 CIT (19%) in the Netherlands. Distributing the remaining EUR 162,000 as dividends costs another EUR 39,690-50,220 in Box 2 tax. Total: EUR 77,690-88,220. The same profit through a Bulgarian EOOD: EUR 20,000 CIT (10%) + EUR 9,000 dividend tax (5% of EUR 180,000). Total: EUR 29,000. That is EUR 48,690-59,220 saved annually.

Step by Step: Planning Your Move from NL to Bulgaria

Get a BV Valuation (6-12 Months Before)

Determine the fair market value of your BV. This is the basis for the conserverende aanslag. Consider getting a formal valuation if the BV holds significant assets, IP, or goodwill. The valuation date will be the date of your emigration, but having an early estimate helps you plan.

Establish Bulgarian Tax Residency

Obtain an address registration in Bulgaria. EU citizens have 4 grounds for residence: company owner, employee, self-sufficient person (EUR 5,100 in a Bulgarian bank), or family member of an EU citizen. Apply for an EU residence permit at the Migration Directorate. Your LNCH (personal number) is issued by the Migration Directorate.

Deregister from Dutch BRP

Visit your gemeente to deregister from the BRP (Basisregistratie Personen) between 5 days before and the day of departure. This automatically notifies the Belastingdienst, health insurers, and pension funds. Your BSN remains valid permanently — you will need it for future Dutch tax filings.

File the M-Biljet

File the M-form for the year of emigration by July 1 of the following year (extensions possible). This is the most important tax filing of your departure — it triggers the conserverende aanslag and establishes the deferral. Work with a Dutch tax advisor to ensure the valuation is accurate and all deferral conditions are met.

Set Up Your Bulgarian Structure

Register a Bulgarian EOOD if you plan to operate from Bulgaria. Open a Bulgarian bank account. Register with the NRA for tax purposes. Apply for a tax residency certificate once you meet the 183-day rule or can demonstrate your centre of vital interests is in Bulgaria.

Maintain Annual Dutch Reporting

File the annual conserverende aangifte with the Belastingdienst confirming you still hold the shares. If you sell, dispose, or donate the shares, the deferred tax becomes payable. If your BV pays you dividends, those are subject to 15% Dutch withholding tax (treaty rate), credited against your Bulgarian tax.

Common Mistakes to Avoid

Mistake	Consequence	How to Avoid
Not filing the M-biljet	Lose deferral rights; Belastingdienst can collect the full conserverende aanslag immediately plus penalties	File by July 1 of the year after departure; request extension if needed
Forgetting the annual conserverende aangifte	Deferral revoked; full amount becomes immediately due	Calendar the annual filing deadline; use a Dutch tax advisor
Not deregistering from BRP properly	Remain Dutch tax resident on paper; dual residency complications; continued Box 3 liability	Deregister in person at your gemeente within the allowed window
Keeping Dutch health insurance too long	Unnecessary premiums; potential Dutch tax obligations	Cancel Dutch health insurance on your departure date; arrange Bulgarian coverage
Selling BV shares immediately after departure	Triggers immediate collection of the entire conserverende aanslag	Plan asset restructuring before departure or wait and use the treaty credit mechanism
Ignoring the 10-year claim period	For AB-claims, the Netherlands retains taxing rights indefinitely (not 10 years). If you sell shares 15 years later, the Dutch claim still applies	Factor the indefinite Dutch claim into long-term planning
Not closing BSN "properly"	Your BSN never expires, but failing to update your foreign address with the Belastingdienst means tax correspondence goes to your old Dutch address	Notify the Belastingdienst of your new Bulgarian address; appoint a Dutch tax representative

Plan Your Move from the Netherlands to Bulgaria

We help Dutch entrepreneurs navigate the conserverende aanslag, set up Bulgarian structures, and obtain tax residency. Free initial consultation, no obligation.

Free. No obligation. Response within 24 hours.

Frequently Asked Questions

What is the Dutch exit tax (conserverende aanslag)? +

The conserverende aanslag is a preserving tax assessment that the Dutch tax authority (Belastingdienst) issues when a taxpayer with a substantial interest (aanmerkelijk belang — 5% or more shares in a company) emigrates from the Netherlands. It treats your shares as if they were sold at fair market value on the day you leave, creating a deemed capital gain subject to Box 2 tax rates of 24.5% on the first EUR 68,843 and 31% above that (2026 rates).

Do I have to pay the Dutch exit tax immediately when moving to Bulgaria? +

No. Because Bulgaria is an EU member state, you are entitled to automatic deferral under ATAD rules. The conserverende aanslag is issued but payment is deferred until you actually sell or dispose of the shares. This deferral is indefinite for substantial interest — it has no 10-year expiry like other conserverende aanslagen. No security deposit is required for intra-EU moves.

What happens to my 30% ruling when I leave the Netherlands? +

The 30% ruling ends immediately when you leave the Netherlands. Since January 2025, partial foreign tax liability (the option to be treated as a non-resident for Box 2 and Box 3) is no longer available for new 30% ruling holders. Transitional rules apply through 2026 for those who had the ruling by end of 2023. When you leave, you must file an M-biljet for the year of departure, declaring worldwide income for the period you were a Dutch tax resident.

How does Bulgaria tax dividend income compared to the Netherlands? +

Bulgaria taxes corporate profits at 10% (CIT) and dividends at 5%, giving a combined rate of 15%. The Netherlands taxes corporate profits at 19% (up to EUR 200K) or 25.8% (above EUR 200K) and dividends at 24.5%-31% via Box 2. For a business earning EUR 200,000 in profit, the total tax burden in the Netherlands is roughly EUR 77,000-88,000 versus EUR 29,000 in Bulgaria.

Does the NL-BG double tax treaty prevent double taxation on my exit tax? +

Yes. The new Netherlands-Bulgaria double tax treaty (effective January 2022) allocates taxing rights to prevent double taxation. When you eventually sell shares that were subject to the conserverende aanslag, credit mechanisms ensure you do not pay tax twice on the same gain. The treaty caps dividend withholding at 15% (general) or 5% (for 10%+ corporate shareholders).

Is Box 3 wealth tax affected when I emigrate? +

Yes, favorably. Once you are no longer a Dutch tax resident, Box 3 liability ends. In 2026, the effective Box 3 rate is approximately 2.80% per year (36% tax on a 7.78% deemed return). Bulgaria has no wealth tax at all. Investment income is taxed at 10% only when actually realized. For someone with EUR 500,000 in investments, this saves approximately EUR 14,000 per year in Dutch wealth tax.

What is the M-biljet and when do I file it? +

The M-biljet (M-form) is a special Dutch income tax return for the year you emigrate. It combines two returns in one: the resident period (worldwide income) and the non-resident period (Dutch-source income only). You must file it by July 1 of the year following your departure, though extensions are possible. Failing to file can result in losing your deferral on the conserverende aanslag and penalties from the Belastingdienst.

Can I keep my Dutch BV after moving to Bulgaria? +

Yes. You can keep a Dutch BV while being a Bulgarian tax resident. The BV remains a Dutch tax resident subject to Dutch CIT (19%/25.8%). Dividends paid to you in Bulgaria are subject to Dutch withholding tax (15%, reduced under the treaty). Many entrepreneurs find it more tax-efficient to establish a Bulgarian EOOD (10% CIT + 5% dividend = 15% combined) alongside or instead of the Dutch BV, and gradually shift operations.