The Netherlands: the Dutch foundation--a vehicle for effective business solutions

The article focuses on the benefits of a Dutch foundation in the form of a Stichting administratiekantoor and the business solutions it offers in holding structures through the issuance of depository receipts that split the legal and the economic ownership rights to the assets which are held by the foundation. Apart from international structuring benefits, the envisaged holding structure reduces the tax rates under an applicable tax treaty and also makes use of the participation exemption offered by Dutch tax law.