A UK Ltd is quicker and cheaper to set up, and it's the natural choice if your customers are in the UK. A Dutch BV takes longer and costs more, but it's an EU-domiciled entity, which matters if you're importing goods into the EU or selling to EU customers, and it can use Article 23 to defer import VAT to your VAT return instead of paying it at the border. Some UK founders run both: a UK Ltd for UK trade and a Dutch BV for EU trade.
The short answer
The deciding factor is almost always where your customers and your goods are. If you're trading only with UK customers, a UK Ltd is faster, cheaper and simpler to run. If you're selling to EU customers or importing goods into the EU, especially as an e-commerce seller, a Dutch BV puts you inside the EU's customs and VAT system directly. An independent Dutch notary handles the legal work of forming it; we coordinate everything around that for you.
At a glance
| Axis | UK Ltd | Dutch BV |
|---|---|---|
| Minimum share capital | £0.01 | €0.01 |
| Time to register | Usually within 24 hours | ~6 working days, best case* |
| Cost to register | £100 (Companies House, online) | From €1,295 ex VAT (notary and KVK fees included) |
| Corporate tax | 25% main rate (19% to £50,000) | 19% to €200,000, 25.8% above |
| Inside the EU customs union | No, since 2021 | Yes |
| VAT and customs | UK VAT only; EU sales are exports | EU VAT; EORI plus Article 23 deferral for imports; OSS for EU B2C |
| Holding company relief | Substantial Shareholding Exemption | Participation exemption (deelnemingsvrijstelling) |
| Non-resident founder banking | Often easier via UK fintech/challenger banks; depends on your residence | Traditional banks often decline without local substance; fintech/EMI accounts commonly used |
| Ownership privacy | Service address and PSC register public | Directors' home addresses not shown; UBO register not public since Nov 2022 |
*Best case for a UK solo founder with an individual shareholding and documents already in English. Typically 2–3 weeks, including collecting your documents and arranging translations. All timelines are estimates, not guarantees.
By use case
- UK-only customers, no importing → a UK Ltd is enough on its own; you likely don't need a Dutch BV yet.
- Selling services or digital products to EU customers → a Dutch BV can use the EU's One Stop Shop scheme (OSS) to report EU-wide B2C VAT from one Dutch registration, rather than registering country by country.
- Importing physical goods into the EU (e-commerce, wholesale) → a Dutch BV, an EORI number and, once your VAT number is issued, our Article 23 support let you clear goods and defer the import VAT to your VAT return instead of paying it at the border.
- Running UK and EU sales side by side → many founders keep the UK Ltd for UK customers and add a Dutch BV for EU customers, invoicing each customer from the entity actually trading with them. See running both, below.
- Long-term running costs → a UK Ltd's ongoing filings are simple and low-cost; a Dutch BV also files annual accounts with the KVK, which you'd arrange through an accountant.
- Raising investment → mixed. UK investors are very familiar with a UK Ltd; EU investors are often more comfortable with an EU-domiciled entity. This is usually led by what your investors want, not a fixed rule.
Privacy
UK Companies House publishes each director's service address (you can use one instead of your home address), full accounts for many small Ltds, and the Persons with Significant Control (PSC) register. On the Dutch side, the KVK doesn't show directors' home addresses, and the UBO register hasn't been publicly searchable since a November 2022 EU court ruling. If keeping ownership details out of a public register matters to you, the Netherlands is generally the more private option.
Tax, the rate question
The UK charges a 25% main rate of corporation tax, with a 19% small-profits rate on the first £50,000 and marginal relief between £50,000 and £250,000. The Netherlands charges corporate income tax (vennootschapsbelasting) at 19% on the first €200,000 of profit and 25.8% above. At small scale the two sit close together; at medium scale the Dutch rate is somewhat lower; at larger scale both land in a similar range, and your actual rate depends on reliefs such as the Innovation Box.
Tax residence: incorporation isn't the whole story
Incorporating in the Netherlands doesn't automatically mean your BV is only ever taxed there, and the same is true in reverse for a UK Ltd: both countries look past where a company is incorporated if it's actually run from somewhere else.
A BV incorporated under Dutch law is treated as resident in the Netherlands for Dutch corporate income tax, because of its incorporation. But if it is effectively managed from another country, that country may also treat it as resident, and tax treaties may assign residence to where the company is effectively managed. That can mean double taxation or the loss of benefits you expected. Where the directors actually make decisions matters, so get tax advice on your own situation.
The UK works on a similar logic: a company can be UK tax resident either because it's incorporated in the UK, or because it's centrally managed and controlled from the UK, whatever its country of incorporation. If you're a UK-based founder making the real decisions for a Dutch BV, that's worth getting advice on before you incorporate. We cover the wider picture, including VAT and banking, in before you start.
This guide is general information, not tax or legal advice. Rules and rates change; check the current position and get advice on your own situation before acting.
VAT and customs after Brexit
Since Brexit, a UK Ltd selling to EU customers is exporting: the sale falls outside UK VAT, and your EU customer, or a customs broker, generally handles the import formalities and any import VAT on the other side. A Dutch BV sits inside the EU's VAT and customs system instead. Intra-EU B2B sales are typically zero-rated, with the customer accounting for VAT (reverse charge), the EU's One Stop Shop scheme (OSS) covers EU-wide B2C VAT reporting from a single Dutch registration, and if you import goods from outside the EU regularly, an EORI number lets your BV clear them. Once your VAT number and turnover-tax number are issued, our Article 23 add-on lets you defer the import VAT to your VAT return instead of paying it at the border. Article 23 has conditions (regular importing, separate import VAT records, monthly or quarterly returns), the Belastingdienst decides within eight weeks, and approval isn't guaranteed. See our Article 23 service for the detail.
Running both
You don't always have to choose between the two. It's common to run a UK Ltd for UK customers and a Dutch BV for EU customers, each entity invoicing the customers it's actually trading with, and an accountant in each country keeping the two straight, including how they account for each other if one recharges costs to the other.
If your UK Ltd, or another company, will hold the shares in the new Dutch BV, that's what our corporate shareholder package is built for: it covers the extra document review, confirmation of signatory authority and beneficial-owner identification a corporate shareholder needs. Article 23 support is available as an add-on to any package if you're importing goods into the EU. See pricing for the full breakdown, or before you start for the things worth knowing first.
FAQ
Yes. Dividends from a qualifying UK Ltd subsidiary up to a Dutch BV parent can qualify for the participation exemption, and a UK Ltd parent's disposal of qualifying shares can use the UK's Substantial Shareholding Exemption. Get advice on your own group structure before setting one up.
Not directly: a Dutch BV is an EU entity, registered under Dutch law, regardless of the UK's status. What Brexit changed is how a UK Ltd trades into the EU. It's now an exporter, and EU customers or a broker often handle the import side, which is one reason UK sellers add a Dutch BV alongside their UK Ltd for EU sales.
Only if you have entities in both. A UK Ltd files its own accounts and confirmation statement with Companies House; a Dutch BV files its own annual accounts and VAT returns in the Netherlands. Running both means keeping both up to date, generally with an accountant in each country.
Mainly for EU customs and VAT. Post-Brexit, a UK Ltd selling into the EU is exporting, and your customer or a broker usually handles the import side. A Dutch BV, an EORI number and, once your VAT number is issued, Article 23 support let you import into the EU yourself and defer the import VAT to your VAT return instead of paying it at the border. Some founders run both entities side by side.
A UK Ltd is usually registered within 24 hours of applying online. A Dutch BV takes longer: our best case, for a UK solo founder with an individual shareholding and documents already in English, is about six working days, and a typical estimate is roughly two to three weeks, including collecting your documents and arranging translations. Both figures are estimates, not guarantees.
Yes. Your BV needs a Dutch business address. We'd love to handle this for you, but Dutch law doesn't allow the firm that helps with your VAT and Article 23 applications to also be involved in your business address. So you arrange it yourself before we begin; it isn't part of our service.
Trading with EU customers or importing into the EU? See how Dutch BV formation works → Or read the full EU jurisdiction comparison →