Paper Profits. Real Taxes. The Dutch Exit Playbook. (Part II)
How to exit the Netherlands strategically, relocate intelligently, and protect long-term capital from valuation-based taxation.
Following The Netherlands move to tax unrealised gains at an eye watering 36%, I wanted to outline a case study where a High Net Worth Individual (HNWI) could move abroad and take advantage of a more advantageous tax structure whilst still being in Europe. Here’s the scenario and the How to ..
Who? A Dutch investor | €1m home | €2.5m US trading income | 36% unrealised gains regime causing her to leave the Netherlands.
Sophie van Dijk, a HNWI who trades US stocks, has just seen the news: from 2028, the Netherlands plans to impose a 36% tax on unrealised gains. That directly impacts her portfolio and trading income. She has no intention of paying tax on paper profits.
An English friend recently moved to Italy under its flat tax regime. Sophie studies the numbers. The €200k flat tax is rising to €300k soon, but even at €300k it is materially lower than what she would face under a 36% annual unrealised gains regime. More importantly, it is fixed. If she earns more, the tax does not rise. That incentive matters to her.
Sophie is married and has a 14-year-old child. This is not a spontaneous move. It is a strategic relocation. She wants to exit the Dutch tax net cleanly, avoid unnecessary taxes, and make the transition smooth for her family.
Here is how she could approach it.
Big Picture Timing Logic
Italy treats you as tax resident if you are resident for more than half of the tax year (generally 183+ days). So, moving in May is strategically smart.
Moving in May ensures:
• She qualifies as Italian tax resident that same year
• She can file an Italian return the following year
• She can obtain an Italian tax residence certificate
• She can demonstrate residence to Dutch authorities
• She avoids drifting into another full Dutch tax year
This synchronises both systems.
24-Month Structured Plan
Assume target Italian residence year = 2027
Preparation begins January 2026.
YEAR −1 (Preparation Year – 2026)
January–March 2026
Strategic Modelling & Reconnaissance
• Confirm Italian eligibility (not resident in Italy 9 of last 10 years)
• Model Dutch exposure under 36% unrealised gains system
• Review classification risk of trading income
• Map full asset base
• Confirm no substantial interest exit complications
Family planning phase:
• Speak with her English friend who already relocated
• Reach out to contacts for recommended neighbourhoods in Milan
• Conduct a scouting trip with her husband
• Visit schools suitable for a 14-year-old
• Begin informal discussions with relocation advisers
This is about eliminating uncertainty early.
April 2026
Sell the Dutch Home — With Speed as Priority
Sophie lists the €1m mortgage-free home.
The gain (€600k) is not taxed in the Netherlands.
However, timing matters.
If selling quickly at €970k instead of holding out for €1m means completing before departure and avoiding exposure to another Dutch tax year, that discount may be financially rational.
The priority is not squeezing the last euro from the sale price.
The priority is synchronising tax residence correctly.
May 2026
Execution Month — The Move
This is the critical pivot.
Actions:
• Physically relocate to Milan
• Sign lease or purchase agreement
• Register at the municipality (Anagrafe)
• Enrol child in school in Milan
• Begin transferring centre of life immediately
Immediately begin accumulating residency evidence:
• Utility bills in her name
• Italian health insurance
• Gym membership
• Local bank account
• Italian mobile contract
• Local professional advisers engaged
This creates a documentary footprint.
This is not a trial move.
This is permanent.
She should also engage:
• Competent Italian tax lawyer
• Italian commercialista (accountant)
• Cross-border adviser if necessary
They must be ready before the first Italian filing season.
June 2026
Sever Dutch Ties Cleanly - Don’t get this wrong.
