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enterprise of the deceased or the giver/donor which is managed in whole or in part using
a Dutch-resident permanent establishment or representative, of which capital the shares
effectively form part of, transition tax will be levied on any received gift or inheritance of
shares by or from a person who at the time of the gift or death was not resident in or
deemed to be resident in the Netherlands. Gift tax and inheritance tax are levied against
the acquiring party.
For levying of Dutch gift tax and inheritance tax, a person with the Dutch nationality who
was resident in the Netherlands, and died or made a gift within ten years after leaving the
Netherlands, shall be deemed to have been resident in the Netherlands at the time of
death or the making of the gift. Furthermore, for levying of Dutch gift tax, any person,
irrespective of his nationality, who was resident in the Netherlands at any time during the
previous twelve months before making or receiving a gift, shall be deemed to have been
resident in the Netherlands at the time of the gift.
Dutch inheritance tax is levied on any received gift of shares from a person not resident in
or deemed to be resident in the Netherlands at the time of the gift, but who died within
180 days of making the gift, and was resident in or deemed to be resident in the
Netherlands at the time of death.
The above mechanism can be altered as a result of applicable double taxation
conventions.
No Dutch gift tax or inheritance tax will be levied on any received gift or inheritance of
shares from a person who at the time of the gift or death was not resident in or deemed
to be resident in the Netherlands.
Capital Tax
Capital tax at a rate of one percent is levied on the payment of shares issued by the
Company. The capital tax paid is deducted from the profit before determination of the
corporation tax.
