The protective assessment: the bill that travels with you, and that never expires for one item

How does the deferral work, and when does the assessment lapse?

If you emigrate to a country of the EU or the EEA, you get an automatic deferral of payment. If you go further away, you apply for the deferral and the Belastingdienst can demand security: a bank guarantee, a mortgage right or a pledge. For pension and annuity that security is not asked as long as the entitlement is held with a Dutch insurer or pension fund, or with an insurer in another EU country, Norway or Iceland. The Belastingdienst's emigration page also names a recognised insurer in Liechtenstein or Switzerland; the explanatory notes to the tax return do not name those two countries. If your pension or annuity is held there, or anywhere else outside the Netherlands, check with the Belastingdienst whether you have to provide security.

The deferral lasts at most ten years. If those ten years pass without you doing anything that makes the assessment collectable, you can ask for remission. Cessation profit works differently: if you put that part back into a business within twelve months, the Belastingdienst sets the assessment to zero and you pay nothing. If you don't, you simply pay tax on it.

If you take your business abroad, something else applies as well. The assets of your business are then treated as sold at market value at the moment you stop living in the Netherlands (Income Tax Act 2001, article 3.60). You settle the tax on that profit when you leave. Have it calculated in advance.

Only the protective assessment for a substantial shareholding is valid indefinitely. So it doesn't expire, and the remission after ten years doesn't apply to it. Whoever keeps their BV and pays out a dividend or sells their shares twenty years later still has to deal with this assessment.

That difference is often overlooked, also in advice that's otherwise correct. "After ten years you're rid of it" is a true sentence about three of the four categories and an untrue one about the fourth. If you have a BV, assume this travels with you as long as the company exists.

Item	Deferral	Lapses or remission
Pension and annuity	automatic in EU/EEA, on request outside it	after 10 years, on request
Endowment insurance owner-occupied home	automatic in EU/EEA, on request with security outside it	after 10 years, on request
Substantial shareholding (≥ 5%)	automatic in EU/EEA, on request with security outside it	never — valid indefinitely
Cessation profit (on request)	12 months to reinvest	zero if reinvested, otherwise pay

When do you have to pay after all?

The assessment becomes collectable if you do something that conflicts with the conditions. For pension and annuity the classic one is: surrendering or disposing of it. If you convert your annuity into a lump sum, the deferral is over.

For a substantial shareholding the triggers are different: you sell your shares, you pay out a dividend, or the company ceases to exist.

What do you do with it?

Three things, and the first is the most important.

Don't be alarmed by the amount. It's not a bill. Within the EU and the EEA the deferral is automatic; you don't have to apply for anything.

Keep the assessment. In ten years, or with a BV in thirty years, it's the document with which you show what was established at the time. You also ask for the remission with it. Put it with the papers you take along and not with the post you clear out.

Have it checked if you have a BV. The combination of a substantial shareholding, an indefinitely valid assessment and a treaty that differs per country is precisely where general information stops. This article explains that it's at play and why it doesn't pass by itself. What it means in your case belongs with a tax adviser.

This is no tax advice. See also when you need an adviser and when not.

In Vertrekklaar this belongs to the phase Closing down the Netherlands of the journey: the same steps, but for your situation — in your order, tickable, and with the deadlines watched. See how the step-by-step plan works.