Moving from the Netherlands to Georgia for the tax rate is the easy part to research. Registering an Individual Entrepreneur and getting Small Business Status takes days, and the 1% is real. What is harder to find is what Dutch law itself does before that rate is legally yours: Article 4 AWR does not release a departing resident on a day count, a 5% shareholding can trigger an exit assessment the moment you leave, and Box 3's wealth tax is mid-reform in a way that changes what counts as taxable while you are still resident. This guide works through what actually has to be true on the Dutch side.
What EUR 80,000 of freelance income actually costs, here and there
Start with the number, because it is the reason anyone reads this far.
A single Dutch zzp'er (self-employed freelancer) with no fiscal partner, earning EUR 80,000 in business profit and meeting the hour criterion, can deduct EUR 1,200 as zelfstandigenaftrek in 2026, then a further 12.7% as mkb-winstvrijstelling, bringing taxable profit to roughly EUR 68,792. Applying the 2026 Box 1 bands published by the Chamber of Commerce - 35.75% to EUR 38,883, then 37.56% above it - produces income tax of approximately EUR 25,134, plus the Zvw health contribution at 4.85% up to a EUR 79,409 cap, roughly EUR 3,851 at this income. Most Dutch freelancers are not compulsorily enrolled in the state pension scheme, so there is no mandatory pension line to add.
| Netherlands (zzp, 2026, single) | Georgia (IE + Small Business Status) | |
|---|---|---|
| Business profit | EUR 80,000 | EUR 80,000 turnover |
| Income tax (Box 1, after deductions) | ~EUR 25,134 | 1% of turnover |
| Zvw health contribution | ~EUR 3,851 | None required by the status itself |
| Total, all-in | ~EUR 28,985 (~36%) | ~EUR 800 (~1%) |
That gap is the entire reason this guide exists, and exactly why Dutch law does not let it happen automatically.
Does Georgia's 1% actually apply to you
The 1% only applies to Georgian-source income, and for services that generally means work physically performed inside Georgia, not work billed through a Georgian registration while you sit in Amsterdam or Rotterdam. We cover the mechanics fully in Georgia's 1% tax and in the honest answer on paying it without living in Georgia. The residency test, exit assessment and CFC position below only matter once someone has genuinely stopped being a Dutch tax resident. Until then, Dutch tax law taxes worldwide income at ordinary progressive rates regardless of where a business is registered.
What the Netherlands does when you leave
Dutch tax residence turns on Article 4 of the Algemene wet inzake rijksbelastingen (AWR), a facts-and-circumstances "centre of life" test - home, family, business activity, bank accounts and other assets, intended length of stay - rather than a day count. No single factor decides it, and someone can spend most of the year abroad and still be assessed resident if enough of the rest of their life stays in the Netherlands.
Every mover eventually deregisters from the Basisregistratie Personen (BRP) into the Registratie Niet-ingezetenen (RNI), within five days of departure. That is a civil registration event, not the Article 4 AWR test itself - a person can complete it and still keep Dutch savings, a family home, or most of their client base behind, and still be assessed resident regardless of what the population register shows. The migration year is filed on the M-formulier, due by 1 July of the following year.
If you hold the 30% ruling, the expatriate facility exempting up to 30% of qualifying salary, leaving ends it immediately with no clawback of what was already received, but also no way to carry the remaining runtime abroad. For rulings starting on or after 1 January 2024, the tax-free percentage steps down to 27% from 1 January 2027, and from 1 January 2026 it only applies to salary up to EUR 262,000, confirmed on I amsterdam's 30% ruling page.
Box 3, the tax on savings and investments, has been under constitutional rebuild since the Hoge Raad's December 2021 "Kerst-arrest" ruled the old flat-yield system unlawful. The system running today taxes category-specific notional returns against a tax-free allowance of EUR 59,357 per person for 2026, with the investment forfait fixed at 6%, confirmed on the Belastingdienst's 2026 Box 3 calculation page; a taxpayer can invoke the tegenbewijsregeling to be assessed on actual return instead if lower. This is not final: the Tweede Kamer passed a flat 36% actual-return regime on 12 February 2026, still needing Senate approval and expected no earlier than 1 January 2028.
If you hold 5% or more of any company, Dutch or foreign - an aanmerkelijk belang - emigrating triggers a conserverende aanslag: your shares are treated as sold at market value on your last day of residence, at the 2026 Box 2 rates of 24.5% to EUR 68,843 and 31% above it. Since 2015 this applies indefinitely, confirmed via Belastingdienst's guidance on the conserverende aanslag at emigration. Payment is deferred rather than collected immediately, but Georgia means requesting that deferral actively and providing security, typically a bank guarantee, rather than the automatic EU/EEA deferral. This only bites a shareholding you already held before leaving, most commonly an existing Dutch BV - a Georgian IE or LLC registered after you have genuinely left is not one.
The CFC-maatregel (article 13ab Wet Vpb 1969) only applies to Dutch corporate taxpayers, not individuals, so a Dutch resident holding a Georgian IE or LLC directly has nothing for it to attach to. The real difference is where the money sits under domestic tax while you remain resident. A Georgian IE has no separate legal personality, so its retained cash is already yours personally and counts as an ordinary Box 3 asset every 1 January reference date, taxed on a deemed return regardless of whether you repatriate it. A Georgian LLC held at 5% or more is a substantial interest taxed in Box 2, which only taxes actual dividends and realised gains - retained profit sits outside annual taxation until you take it out or emigrate. Below 5%, a foreign shareholding falls back into Box 3, and none of this matters once residency is genuinely broken, since non-resident Box 3 only reaches Dutch-situated assets such as real estate. The fuller comparison, including the Georgian side, is in Individual Entrepreneur vs LLC.
The Netherlands and Georgia have had a double taxation convention in force since 21 February 2003, applying from 1 January 2004, confirmed on wetten.overheid.nl. It resolves genuine residency disputes but does nothing to change Article 4 AWR, Box 3, or the conserverende aanslag, all domestic law. The Dutch low-tax list tests for a statutory corporate rate of 9% or less - Georgia's statutory rate is 15%, so its 0% treatment of retained profit does not put it on the 2026 Dutch list, and there is no separate personal blacklist like Spain's or Italy's.
Dutch state pension accrual (AOW) and mandatory health insurance (Zvw) both stop once you have genuinely left; AOW freezes at whatever percentage already accrued, with voluntary continuation available for up to ten years if you apply within a year of leaving. We found no bilateral social security agreement between the Netherlands and Georgia, consistent with Georgia's generally thin totalisation network described in our country-by-country guide, so this affects benefit eligibility later rather than creating a double social-charge problem.
The steps, in order
- Confirm Article 4 AWR is genuinely closed - home, family, business activity and assets all have to have actually moved, not just your civil registration.
- Deregister from the BRP into the RNI within five days of departure, and file the M-formulier for the split tax year by the following 1 July.
- If you hold the 30% ruling, accept the forfeited runtime - there is no way to carry it to Georgia.
- Check whether you already hold 5% or more of any company. If so, value the conserverende aanslag exposure and arrange deferral and security before departure, not after.
- Register a Georgian Individual Entrepreneur and apply for Small Business Status, either in person or under power of attorney through remote company registration.
- Choose an IE over an LLC if you want retained profit out of annual Box 3 taxation, since an LLC's retained profit does not until distribution or emigration.
- Confirm your Georgian tax residency position separately, since Small Business Status does not by itself make you tax resident here.
Timeline and cost
The Georgian side is fast: a few days in person, or two to three weeks under power of attorney. The Dutch side takes longer if done properly - confirming Article 4 AWR against your actual ties, the five-day BRP window, and any conserverende aanslag deferral and security before you go. Budget weeks rather than days for that half.
The verdict for a Dutch national
Georgia is a strong fit for a Dutch national who genuinely relocates. There is no Dutch equivalent of Germany's decade-long extended liability or Spain's trailing rule, Georgia is not on the Dutch blacklist, and CFC rules do not reach an individual holding either structure directly. What matters is narrower: genuinely shift the centre-of-life factors under Article 4 AWR, resolve any existing 5% shareholding first, and choose between an IE and an LLC based on how long you expect to keep filing as a Dutch resident.
We'll work through your Article 4 AWR residency position, whether a conserverende aanslag applies to anything you already hold, and whether an IE or an LLC makes more sense given your Box 2 and Box 3 exposure, before you register anything here. Written summary included.
See what it costs
For the same analysis built for a different departure point, see our guides on moving from Italy to Georgia and moving from Spain to Georgia, and for how Georgian-source income is actually defined, see Georgian-source income rules. A free consultation is the fastest way to find out where your own situation actually lands.
Key takeaways
- Confirm Article 4 AWR is closed on the facts, not just civil registration, before assuming BRP deregistration has ended Dutch residency.
- File the M-formulier for the split departure year by the following 1 July.
- If you hold 5% or more of any company before leaving, arrange the conserverende aanslag deferral and security before departure, not after.
- Accept that a 30% ruling forfeits its remaining runtime the day you leave.
- Pick an IE if you want retained profit out of annual Box 3 taxation; pick an LLC only once you understand it sits in Box 2 instead.
- Register the Georgian IE and Small Business Status only once the Dutch side above is genuinely resolved.
Frequently asked questions
Does moving to Georgia automatically end my Dutch tax residency?
No. Article 4 AWR is decided on the totality of facts and circumstances - where your home, family, work and assets actually are - not by any single administrative step. Deregistering from the BRP is a civil registration event and does not by itself prove your centre of life has moved.
What is the conserverende aanslag and does it apply to my Georgian company?
It is an exit assessment triggered when someone holding 5% or more of a company's shares emigrates - the shares are treated as sold at market value on the day residency ends. It applies to a shareholding already held before leaving, most commonly an existing Dutch BV, not to a Georgian IE or LLC set up as part of the move.
Is Box 3 still going to tax my savings while I decide on the move?
Yes, as long as you remain Dutch resident. The current notional-return system, revised after the Hoge Raad's Kerst-arrest, taxes savings and investments against a EUR 59,357 allowance, with actual-return counter-evidence available if lower. A genuinely new flat actual-return regime is due no earlier than 2028.
Do Dutch CFC rules reach a Georgian IE or LLC I own personally, and are the two taxed the same?
No, not directly - the CFC-maatregel under article 13ab Wet Vpb 1969 only applies to Dutch corporate taxpayers, not individuals. But the two structures are not taxed alike: while you remain resident, a Georgian IE's retained cash counts as your personal Box 3 wealth every year, while a Georgian LLC held at 5% or more is a Box 2 substantial interest, taxed only when you take money out or sell.
Is Georgia on the Dutch blacklist of low-tax jurisdictions?
No. The Dutch list covers jurisdictions with a statutory corporate tax rate of 9% or less, plus the EU's non-cooperative list. Georgia's statutory rate is 15%, so it does not meet the test regardless of how retained profit is timed under Georgia's own distribution-based system.
What happens to my 30% ruling if I move to Georgia?
It ends immediately. Your final Dutch payslip is taxed at ordinary rates with no exemption, and there is no way to carry any remaining years abroad. There is no clawback of the benefit already received, but nothing about the ruling survives departure.
Does the Netherlands-Georgia tax treaty stop the conserverende aanslag or Box 3 from applying?
No. The treaty, in force since 2004, resolves residency disputes. It has no effect on the conserverende aanslag or on Box 3, both purely domestic Dutch law.