Leaving the Netherlands for Dubai: the bill that never expires

The Netherlands does not let you leave quietly. It sends you a bill on the way out, calculated on gains you have not realised and on a pension you cannot touch for decades, and it calls that bill a conserverende aanslag, a protective assessment.

The word protective is misleading. It suggests something dormant. For one half of it that is roughly true. For the other half, since 15 September 2015, it is not true at all.

Part one: your shareholding

The end of your unlimited Dutch tax liability counts as a deemed disposal of a substantial shareholding, under article 4.16 paragraph 1 letter h of the Wet IB 2001. The provision also catches the case where you simply stop being a resident under a tax treaty.

A shareholding is substantial at 5 percent of the paid-in capital, the acquisition rights, the profit shares or the voting rights, held alone or together with your partner, under article 4.6. Where a company has several classes of share, 5 percent of one class is enough. The Box 2 rate for 2026 is 24.5 percent up to 68,843 euro and 31 percent above it, plus a base amount of 16,866 euro. The figure of roughly 67,000 euro that circulates online is the 2025 bracket.

The deferral, and why Dubai costs more than Berlin

Deferral of payment runs through article 25 paragraph 8 of the Invorderingswet 1990. Three points decide the cost:

1. It is granted only on written request and only against sufficient security.
2. The exemption from both the request and the security applies exclusively to a move to another EU member state. The Emirates are not one, so providing security is mandatory.
3. No invorderingsrente accrues while the deferral runs, under article 28 paragraph 3.

Security means real security: a bank guarantee, a pledge, a mortgage. It is capital that stops working for you for as long as the assessment stands.

The part with no end date

For departures from 15 September 2015 onwards there is no ten year period and no automatic remission for the substantial shareholding. The deferral runs indefinitely, which is another way of saying the claim sits there for the rest of your life.

Remission under article 26 is possible where the shares lose value, where the outcome is worse than a purely domestic case, and to the extent of tax actually levied in your country of residence. That last route is the one advisers reach for, and in the Emirates it leads nowhere, because no tax is levied there on private capital gains.

What ends the deferral and makes the money payable: selling the shares, distributing reserves, so paying yourself a dividend, and repaying paid-in capital. The dividend catches more people than the sale, because it feels like ordinary business.

Part two: your pension

This is the half that is regularly missed until the assessment lands.

At the end of unlimited tax liability, the market value of your accrued pension entitlements is added to your wages under article 3.83 paragraph 1, and deducted lijfrente premiums plus return are treated as negative expenditure on income provision under article 3.136.

On top of the tax there is the revisierente: 20 percent of the market value of the entitlements, under article 30i of the Algemene wet inzake rijksbelastingen. Not 20 percent of the tax. Twenty percent of the value.

The deferral rules here are friendlier. Under article 25 paragraph 5, no request and no security are needed when the entitlements sit with an insurer in the Netherlands, an EU state, Norway, Iceland, Liechtenstein or Switzerland. What matters is the seat of the insurer, not the destination country. A Dutch pension fund stays security-free even when you move to Dubai.

And here the ten year rule genuinely exists: the deferral ends on the first day of the tenth year after the assessment year, and the open amount is then remitted on written request. On request. Nobody sends it to you.

	Substantial shareholding	Pension and lijfrente
Security required for a move to Dubai	yes	no, if the insurer sits in the NL, EU, NO, IS, LI or CH
Ten year remission	none, for departures from 15.09.2015	yes, on written request
Surcharge on top of the tax	none	20 percent revisierente

Inheritance tax follows you for ten years

Article 3 of the Successiewet 1956 contains two fictions. Paragraph 1 treats a Dutch national who lived in the Netherlands and dies or makes a gift within ten years of leaving as still resident there. It applies only to Dutch nationals, but it covers deaths and gifts alike. Paragraph 2 treats anyone who makes a gift within one year of leaving as still resident, regardless of nationality.

For a Dutch national moving to Dubai the effect is straightforward: ten years of worldwide exposure to Dutch inheritance and gift tax. The Dubai Marina apartment is inside it. So is the brokerage account opened here.

Taxable acquisition	Partner and direct descendants	All other cases
0 to 158,669 euro	10 percent	30 percent
from 158,669 euro	20 percent	40 percent

The 2026 exemptions run from 828,035 euro for a partner down to 26,230 euro for each child or grandchild. There is no estate and gift tax treaty with the Emirates. The 2007 treaty covers taxes on income only.

Why the treaty does not rescue you

Article 4 paragraph 1 letter b of that treaty defines a resident of the Emirates as “an individual who is a national of the United Arab Emirates”, with the further requirements of substantial presence, a permanent home or habitual abode and closer personal and economic relations with the Emirates. A Dutch national on a UAE residence visa is therefore not a treaty resident, neither for the tie-break rule nor for protection against Dutch taxation at source.

Article 13 allocates gains on shares exclusively to the seller’s state of residence, without the substantial shareholding reservation found in most recent Dutch treaties. That does not help against the conserverende aanslag, because the deemed disposal bites in the last moment of unlimited tax liability, while you are still a Dutch resident. Article 17 lets the source state tax pensions and benefits such as the AOW, so the Netherlands keeps the taxing right.

The smaller items that still cost money

• Healthcare and social security stop with no substitute. Cover under the Zorgverzekeringswet ends with deregistration and an actual move, the Emirates are not a treaty country for medical care, and there is no social security agreement with them.
• Your AOW shrinks by 2 percent per uninsured year. Voluntary continued insurance is capped at ten years, must be applied for within one year of moving, and costs 17.9 percent of income for 2026, between 569 and 5,693 euro.
• Kinderbijslag ends, because entitlement is excluded where the child does not live in the Netherlands on the first day of a calendar quarter. The kindgebonden budget goes with it.
• A retained property stays in Box 3, at 36 percent on a deemed return of 6 percent, with debts deducted at 2.61 percent. The mortgage interest deduction is gone, because qualifying non-resident status requires the EU, the EEA, Switzerland or the BES islands.
• Deregistration is a deadline. Anyone expecting to spend more than eight months of a year abroad must report the departure between the fifth day before the travel date and the travel date itself.

What this means in practice

The Dutch exit is not one decision. It is a sequence, and the order changes the number.

1. Establish whether you hold a substantial shareholding at all. Five percent of one class of share is enough, and a partner’s holding counts with yours.
2. Arrange the security before you leave. It is a negotiation with the ontvanger, and it goes better from Amsterdam than from Dubai.
3. Check where your pension actually sits. An insurer in the Netherlands or the EU keeps the deferral free of security, and moving the pot first can quietly destroy that.
4. Diarise the pension remission. It falls due on the first day of the tenth year after the assessment year, on written request, and only if someone asks.
5. Count ten years for the Successiewet and decide what you want to give, and when, inside that window rather than after it.

The Dubai side is the simple half. A company, a residence visa, an Emirates ID, a corporate tax registration, all with published fees and fixed deadlines, and you can work the first year out yourself in our company cost calculator.

The expensive half is the country you are leaving, and the Netherlands is a harder case than most. It is harder than the United Kingdom, which has no exit tax at all and relies on inheritance tax and pension charges instead.

We handle the UAE side, the accounting, the tax registrations and the deadlines. The Dutch side belongs with a Dutch adviser who works with the conserverende aanslag regularly, and it belongs there before the move, not after it.

This article is part of a series comparing what leaving costs across fifteen countries. The overview, with a table of every exit charge and how long each tail runs, is in what leaving costs, by country.