As the tectonic plates of European finance continue their relentless shift post-Brexit and in the shadow of ever-stricter global tax regimes, two cities remain unassailable pillars for the world’s most discerning investors, private capital groups, and multinational strategists: London and Amsterdam.
The City of London stands unmatched as the beating heart of global deal origination, capital formation, and legal craftsmanship. Far from being eclipsed by Brexit, the UK’s tried-and-tested company law—anchored in LLPs, Private Limited Companies, and the enduring flexibility of English trust law—continues to seduce international capital. Thanks to the advocacy and ongoing research of organisations such as TheCityUK London’s gravitational pull is reinforced by its deep secondary markets, world-renowned dispute resolution under English law, and the unrivalled prowess of its legal and advisory ecosystem. Structures such as the Limited Liability Partnership (LLP) and Private Limited Company (Ltd) remain the gold standard for fund managers, cross-border holding strategies, and asset-rich families seeking sophisticated risk segregation, directorial liability limitation, and fiscal neutrality. The enduring utility of English trusts in asset protection, dynastic succession, and philanthropic frameworks is as robust as ever—fully tested, and City-certified.
With the UK’s hybrid capital structures and flexible non-dom regime, it’s not uncommon to see overall effective tax rates on international investment flows compressed to 10–15%, especially for groups that meet the new substance and reporting standards.
Meanwhile, Amsterdam has, almost stealthily, asserted itself as the EU’s foremost bastion of compliance and operational substance. The Dutch BV (Besloten Vennootschap), long favoured as a holding “box,” has evolved: Article 13 CITA (the participation exemption), direct access to over ninety double tax treaties, and the seamless interface with EU cross-border structuring make it an anchor for pan-European value chains. The @Dutch Chamber of Commerce in the UK and the Netherlands Foreign Investment Agency (NFIA) have both played instrumental roles in fostering bilateral understanding and smoothing the pathway for international groups seeking to establish substance in the Netherlands. It’s typical for dividends and capital gains routed through a Dutch BV—provided substance requirements are met—to be taxed at effective rates as low as 0–5% under the participation exemption regime. The Dutch embrace of ATAD anti-abuse rulebook, DAC6 hallmarks, and UBO register transparency is now a competitive advantage rather than a compliance burden. Robust local governance, mandatory Country-by-Country Reporting, and real economic presence are not optional: they are the passport to reputational resilience and long-term viability in a scrutiny-driven landscape.
How do these models truly compare? The UK’s international platform, with its gateway to the Commonwealth and a persistent culture of legal innovation, still offers flexibility for global expansion and capital mobility—often reducing the overall group effective tax rate by 20–25% when combined with strategic use of LLPs and trusts. The Dutch model, by contrast, delivers seamless EU market access and a shield of regulatory credibility that is the envy of the continent. Yet both jurisdictions now share a relentless focus on substance—real management, boots-on-the-ground decision making, and airtight compliance. The age of the “letterbox” company is, quite simply, history.
So, why pursue both? Astute players in 2025 are orchestrating dual-anchored structures: a Dutch BV as the EU anchor, underpinned by legal substance and treaty access, complemented by a UK LLP or Ltd for global capital markets, fundraising, or wealth planning. This twin-track architecture, when properly engineered, can compress consolidated group tax rates by 25–35% compared to legacy single-country structures—all while passing the strictest BEPS, ATAD, and Pillar 2 tests.
In practice, leading multi-jurisdictional networks—such as those supported by the NBCC are setting new standards in cross-border governance, regulatory transparency, and operational excellence. The playbook for global business leaders is clear. Harness London’s legal ingenuity, deploy Amsterdam’s substance and transparency, and future-proof your structures against the onslaught of BEPS, Pillar 2, and the next wave of regulatory scrutiny. Assemble teams with real operational gravitas. Document every process, anticipate every audit. In a Europe that increasingly penalises the superficial, mastery of the London-Amsterdam axis will remain the mark of winners.
London, October 2025
