Form 5472 for Dutch Owners of a US LLC
Dutch owners of a single-member US LLC may need Form 5472 and a pro forma 1120. Learn the BSN or RSIN, transaction and filing rules.
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Last updated August 19, 2026
A Netherlands resident who wholly owns a US single-member LLC generally files Form 5472 with a pro forma Form 1120 when the LLC has a reportable transaction with its owner or another related party. Capital contributions, withdrawals, loans, reimbursements and formation expenses can create the obligation even if the company earned no revenue.
The filing gives the IRS related-party information. It does not decide Dutch tax classification or replace a Netherlands return. The IRS Form 5472 instructions state that a required Form 5472 filed late, filed substantially incomplete, or not supported by required records can trigger a $25,000 penalty. A Dutch owner can start a guided filing after collecting the LLC EIN, owner information and transaction ledger.
Does a Dutch-owned US LLC have to file Form 5472?
A Dutch-owned US LLC generally files Form 5472 when the LLC is a domestic disregarded entity wholly owned by a foreign person and it had a reportable transaction with the owner or another related party. The IRS instructions include foreign-owned US disregarded entities in the definition of reporting corporation for section 6038A purposes.
Use a five-step check:
- The entity was created under US state law.
- The entity had one owner for US federal tax purposes.
- The owner was a Dutch individual, Dutch legal entity, or other non-US person.
- The LLC did not elect corporate tax treatment.
- Money, property, services or another item of value moved between related parties during the year.
The fifth item is broader than sales. A no-revenue LLC can still have a filing obligation if the owner funded the bank account, paid formation costs personally, took a withdrawal, loaned money to the LLC, or dissolved the entity and received remaining funds.
For filings due in 2026, the 2025 calendar-year Form 5472 package was generally due 15 April 2026 under the IRS Form 5472 instructions. A timely Form 7004 extension generally moved the due date to 15 October 2026. The IRS instructions require foreign-owned US disregarded entities to file the extension request by the regular due date.
Does the owner use a BSN or RSIN as the FTIN?
A Dutch individual owner generally uses the Burgerservicenummer, or BSN, as the FTIN when applicable. The Netherlands Tax Administration says a BSN is a unique personal number for anyone who has contact with the Dutch government, and that a business receives either a BSN or a Legal Entities and Partnerships Information Number, or RSIN, depending on legal form, in its BSN guidance.
Use the legal owner to select the identifier:
| Owner type | Identifier to review |
|---|---|
| Dutch individual | BSN |
| Sole proprietor or business using the owner's personal number | BSN, if that is the relevant tax identifier |
| Dutch legal entity | RSIN or other applicable entity tax identifier |
| Owner with an existing US number | SSN, ITIN or EIN in the separate US-ID field |
| Owner with no FTIN | "None" or "N/A" only where the IRS instructions permit it, plus a reference ID where required |
Do not put the US LLC's EIN in the Dutch owner's FTIN field. The EIN belongs to the reporting entity. The BSN or RSIN belongs to the foreign owner.
What does the US-Netherlands treaty change for Form 5472?
The US-Netherlands income tax treaty may affect US income-tax analysis, but it does not remove Form 5472. The IRS treaty A-to-Z page lists the Netherlands among countries with US income tax treaty documents.
A treaty position is about allocating taxing rights over income. Form 5472 is about reporting related-party transactions by a US reporting entity. A Dutch owner can have no US corporate income tax at the LLC level and still have a Form 5472 filing because the LLC is treated as a corporation solely for section 6038A reporting.
| Question | Dutch owner answer |
|---|---|
| Does the LLC pay US corporate tax by default? | Usually no if it remains a disregarded entity |
| Does the owner owe US income tax? | Depends on US trade or business, source and treaty facts |
| Does the treaty cancel Form 5472? | No |
| Does zero revenue cancel Form 5472? | No, if a reportable transaction occurred |
| Does Dutch tax classification cancel Form 5472? | No |
Form5472 Prep is not a CPA firm and does not give tax advice. Use a Dutch adviser for Dutch classification, VAT, Box analysis, payroll or local filing questions. Use a US adviser where the LLC has US workers, US inventory, US real estate, US services or other facts that may create US income-tax exposure.
What related-party transactions need review?
The Dutch owner should review both directions of value movement between the owner and the LLC. The Form 5472 workpaper should be an owner ledger, not only a profit-and-loss statement.
| Category | Examples | Why it appears in the workpaper |
|---|---|---|
| Contributions | Initial USD funding, later capital transfers | Owner-to-LLC movement |
| Withdrawals | Distributions, draws, personal expenses paid by the LLC | LLC-to-owner movement |
| Loans | Advances, repayments, interest | Related-party debt |
| Reimbursements | Personal card paid LLC expense, LLC later repays | Two related-party steps |
| Services and property | Management services, licence rights, equipment | Non-cash or service transactions |
| Lifecycle events | Formation, acquisition, disposition, dissolution | Part V narrative facts |
Payment platforms do not decide reportability. A Mollie, Stripe, PayPal or Wise transfer from an unrelated customer is different from a transfer between the LLC and the Dutch owner. The owner relationship, not the payment rail, is the key distinction.
The reportable transactions guide gives examples of owner contributions, distributions, loans and reimbursements.
How are euro amounts converted to dollars?
Euro amounts should be converted into a US-dollar schedule that supports the amounts on Form 5472. The IRS instructions ask for total related-party transaction values in US dollars, so keep the date, EUR amount, exchange-rate source, USD amount and transaction label together. The IRS yearly average currency exchange rates page is the recommended source when a yearly average is appropriate; use transaction-date support when the facts call for spot rates.
Worked example:
| Transaction | Original amount | Working | USD workpaper amount |
|---|---|---|---|
| Owner contribution | EUR 3,200 | EUR 3,200 x 1.0900 | USD 3,488 |
| Owner reimbursement | EUR 350 | EUR 350 x 1.0800 | USD 378 |
| Owner withdrawal | EUR 1,000 | EUR 1,000 x 1.0700 | USD 1,070 |
| Total related-party value reviewed | USD 3,488 + USD 378 + USD 1,070 | USD 4,936 |
The exchange rates in the table are illustrative, not official. Replace them with documented rates from the transaction dates or another consistently used published source. The workpaper should make the USD amount reproducible without guessing.
How does a Dutch owner file the return?
The Dutch owner files through the US LLC by preparing a pro forma Form 1120 with Form 5472 attached. The IRS instructions say "Foreign-owned U.S. DE" should be written across the top of Form 1120 and that foreign-owned US disregarded entities file by fax at 300 DPI or higher to 855-887-7737, or by mail to the dedicated Ogden PIN Unit address.
Follow this procedure:
- Confirm the LLC's legal owner, tax classification and tax year.
- Collect the LLC EIN and the Dutch owner's BSN, RSIN or other applicable identifier.
- Reconcile all owner and related-party transactions.
- Convert non-USD amounts and save the calculation schedule.
- Prepare Form 5472, the Part V statement and the pro forma Form 1120.
- Review the package for names, addresses, EIN, FTIN, reference ID and transaction totals.
- Fax or mail the signed package to the dedicated IRS Ogden PIN Unit address in the instructions.
- Keep the signed package, ledger and timestamped proof of filing.
Foreign-owned US disregarded entities cannot e-file Form 5472 under the IRS instructions. A Dutch owner should keep the fax receipt or mailing proof with the return because late-filing notices may arrive long after the deadline.
How should a Dutch owner think about Dutch tax?
Dutch tax treatment is separate from Form 5472, and Netherlands residents should get local advice before deciding how the US LLC is treated at home. The Netherlands Tax Administration says a person living in the Netherlands with income from abroad has to state Dutch income and income from abroad together as worldwide income in its income-from-abroad guidance.
That local analysis can involve classification, double-tax relief, VAT, payroll and business-registration consequences. Form 5472 does not answer those questions. Form 5472 only reports related-party transactions required under US information-reporting rules.
Four scenarios, worked through
Dutch consultant, Wyoming LLC, all services performed from Amsterdam. The owner works outside the United States and has no US employees or office. US income-tax analysis depends on the full facts and treaty position, but the owner contributed EUR capital and later withdrew funds. Form 5472 is generally required for the related-party transactions.
Dutch ecommerce seller, Delaware LLC, inventory in a US warehouse. US inventory creates a meaningful US tax question. The Form 5472 filing remains separate. Owner loans, reimbursements, distributions and other related-party transfers should be collected while the income-tax position is reviewed.
Dutch SaaS founder, New Mexico LLC, no revenue in 2025. The owner paid formation costs and registered-agent invoices personally. No customer revenue does not eliminate the owner-paid expense. The 2025 package was generally due 15 April 2026, or 15 October 2026 after a timely extension.
Dutch owner dissolving an inactive LLC. The owner pays final costs, receives remaining bank cash and closes the LLC. Closing-year transactions can still be reportable. The owner should file the final Form 5472 package before treating the US entity as finished.
How can Form5472 Prep be the answer?
Form5472 Prep is the practical answer when the Dutch owner needs the US information-return package prepared, reviewed and sent to the IRS. The service prepares Form 5472, the pro forma Form 1120 and the Part V statement, and the package is reviewed by a qualified tax accountant.
After signature, Form5472 Prep faxes the package to the IRS Ogden PIN Unit at 855-887-7737 and returns a timestamped receipt. Standard service is $149 and takes 5-7 business days. Express service is $199 and takes 3 business days. Each additional past tax year is +$99. Fax delivery is included.
If the LLC still needs an EIN, the EIN service is $149 at /ein. Form5472 Prep is not a CPA firm and does not give Dutch or US tax advice, but it does handle the preparation and fax-submission work that cannot be done through normal e-file software.
Frequently asked questions
Does a Dutch owner need an ITIN for Form 5472?
Usually no. The LLC needs an EIN. A Dutch owner generally uses the applicable BSN or RSIN as the FTIN and a reference ID where required.
Is the KvK (Dutch Chamber of Commerce) number always the FTIN?
Do not assume so. Match the identifier to the legal owner and its tax records. Individuals generally use BSN; legal entities generally review RSIN or another applicable entity tax identifier.
Does a Dutch-owned LLC with no income file Form 5472?
It can. Funding, personally paid costs, withdrawals, loans, reimbursements and dissolution activity can be reportable even when the LLC had no sales.
Does the US-Netherlands treaty remove Form 5472?
No. The treaty can affect US income-tax analysis, but Form 5472 is a separate information return for related-party transactions.
Can a Dutch owner e-file Form 5472?
No. The IRS instructions say a foreign-owned US disregarded entity cannot file Form 5472 electronically. The package is faxed or mailed to the Ogden PIN Unit.
Does Form 5472 determine Dutch tax?
No. Form 5472 is US information reporting. Dutch classification, worldwide income, VAT and double-tax relief questions require separate Dutch professional advice.
What should Dutch owners do next?
Accurate owner identification and a reconciled ledger solve most preparation problems. Start your filing, or use the foreign-owned LLC filing checklist to confirm the rest of the annual package.