UK Ltd is faster (24-hour formation), cheaper (~£12 to incorporate), and has no minimum capital, but the UK is outside the EU. Dutch BV is slower (5 days) and pricier (~€1,300+), but inside the EU customs union with Article 23 VAT deferment and the participation exemption. For UK-customer businesses pick the UK; for EU-customer businesses pick the Netherlands.
The short answer
The deciding factor is almost always where your customers are. Selling to UK customers? A UK Ltd is faster, cheaper and simpler. Selling to EU customers, importing goods, or wanting EU-domicile credibility? The Dutch BV's structure pays for itself.
At a glance
| Axis | UK Ltd | Dutch BV |
|---|---|---|
| Minimum capital | £0.01 | €0.01 |
| Setup time | 24 hours | 5 working days |
| Setup cost | ~£112 | €1,295 all-in |
| Corporate tax | 25% (19% ≤£50k) | 19% (≤€200k) / 25.8% |
| In the EU? | No (Brexit, 2020) | Yes |
| VAT regime | UK VAT, standalone | EU VAT + Article 23 + OSS |
| Holding regime | Substantial Shareholding Exemption | Participation exemption |
| Bank account (non-res) | Easy (Wise, Starling, Monzo) | Fintech easy (Revolut, Wise) |
| Director address public? | Yes, on Companies House | Redacted; UBO not public |
By use case
- UK-customer SaaS or consulting → UK Ltd. Faster, cheaper, simpler, with no EU friction needed.
- EU-customer SaaS or services → Dutch BV. It avoids per-country VAT registration, OSS covers EU B2C, and EU enterprise customers prefer EU-domiciled vendors.
- E-commerce shipping goods to the EU → Dutch BV. Post-Brexit, a UK Ltd shipping to EU customers acts as an exporter and the customer or broker handles import. Article 23 plus NL VAT registration is far cleaner.
- Dual UK + EU presence → both. Many founders run a UK Ltd for UK ops and a Dutch BV for EU ops, the standard post-Brexit dual setup.
- Cheapest passive holding → UK Ltd. Annual filing costs are minimal (~£100/year). A Dutch BV runs ~€2,650/year.
- Investor-facing, fundraising → mixed. UK Ltd is familiar to UK/US/global investors; the Dutch BV is familiar to EU investors. Preference is usually investor-led.
Privacy
UK Companies House makes director addresses (residential or service), accounts (in full for many small Ltds), and PSC (Persons of Significant Control) publicly searchable. On the Dutch side, KvK redacts director addresses (only the registered office is shown) and the UBO register has not been publicly searchable since the November 2022 CJEU ruling. For privacy-conscious founders, the Netherlands is materially better than the UK.
Tax, the rate question
The UK charges a 25% main rate, with a 19% small-profits rate below £50,000 and marginal relief between £50k and £250k. The Netherlands charges 19% on the first €200,000 and 25.8% above. At small scale both sit near 19%. At medium scale the Netherlands is moderately cheaper (19% versus 25%). At large scale both land around 25–26%, and effective rates depend on the Innovation Box and R&D credits.
VAT, the structural difference
A UK Ltd is VAT-registered in the UK only; EU sales are exports and EU customers handle import VAT. A Dutch BV is EU VAT-registered, with intra-EU B2B reverse-charged, Article 23 for non-EU imports, and OSS for EU B2C. For any EU-customer-facing business, the Dutch BV is structurally simpler.
The dual UK + EU setup
Many UK founders run a UK Ltd for UK operations and a Dutch BV for EU operations: the Dutch BV invoices EU customers, the UK Ltd invoices UK customers, and the group cross-charges via management fees. This is the standard post-Brexit pattern, and we commonly form the Dutch BV for existing UK Ltd holders.
FAQ
Yes. The Dutch participation exemption and the UK Substantial Shareholding Exemption work together cleanly.
No. The Dutch BV is an EU entity, unaffected by the UK's status.
Only if you have entities in both. A single Dutch BV files only in the Netherlands.
It depends on your customer mix. A UK Ltd is famously easy and friendly to US founders; the Dutch BV offers Article 23 and EU credibility. See our BV vs Delaware comparison.
UK Ltd strike-off is ~£10 plus filing. Dutch BV turbo liquidation is ~€795; a formal Dutch liquidation is from ~€1,895.
For EU customers, the Dutch BV pays off. Start here → Or read the full EU jurisdiction comparison →