Pioneering Regenerative Hospitality

At Rawness, we’re not just building a hospitality brand; we’re accelerating the global transition to a regenerative economy. Our Regenerative Impact Shares offer investors a unique opportunity to earn a stable return while driving transformative environmental, social, and cultural impact through regenerative private stays.

We operate one single share class priced at Holding NAV per share; reinvestment does not create new shares (no dilution), and repurchased shares are cancelled.
 

Our Approach to Tax Optimization at Rawness

At Rawness, we envision a world where prosperity flows from deep harmony with nature and communities. To bring this vision to life, we structure our finances thoughtfully and transparently, leveraging tax-efficient jurisdictions and double taxation treaties. This enables us to channel resources efficiently toward regenerative projects that restore ecosystems and uplift local economies. In practice, each property sits in its own local SPV/OpCo (ring-fenced) owned by a Dutch Holding BV. Operating profits are taxed locally; eligible distributions then flow to the Holding under EU/ treaty rules. Dividends paid from the EU SPV/OpCo to the Dutch holding can qualify for a 0% withholding tax under the EU Parent–Subsidiary Directive (subject to conditions like minimum shareholding and substance), and incoming dividends are exempt from Dutch corporate income tax under the participation exemption.

Substance matters: board decisions, records and functions must sit in the Netherlands (arm’s-length fees, real presence) to secure PSD 0% WHT and Dutch participation exemption. Anti-abuse rules apply.

 

Why This Matters

Tax optimization plays a key role in our framework because it safeguards value that might otherwise diminish, allowing us to invest more robustly in bottom-up regenerative efforts, grassroots projects powered by investor support. It helps keep prices for our products and services accessible, expanding the reach of the regenerative economy and accelerating positive change.

The regenerative economy represents a fundamentally different way to shape a business: it revolves around harmony in all aspects - economic, operational, and in our relationship with nature and its cycles - to prevent any form of extraction and foster cycles of renewal. By aligning financial strategies with environmental and social priorities, we direct resources toward meaningful outcomes, all while upholding full transparency and compliance.

We invite you to reflect on this approach and decide if it resonates with your values. True regeneration emerges from intentional decisions that amplify impact where it's needed most.

Efficient EU Structure

Rawness projects will be operated through a local company in the country where each stay is built, held under an EU-based holding.

For Rawness, this holding is typically a Dutch BV. This structure:

• Allows tax-efficient profit flow (deductible interest & fees, reduced withholding under treaties). Within the EU, dividends from a qualifying subsidiary to its EU parent can be paid with 0% withholding under the Parent–Subsidiary Directive (subject to minimum shareholding and substance). Taxation and Customs Union+1

• Keeps Rawness fully compliant with international standards (arm’s-length pricing, local substance). At the Dutch holding level, the participation exemption generally exempts qualifying dividend income from Dutch corporate income tax. 

• Provides investors with streamlined participation and reporting.
   

Returns shown are after local corporate tax; final net yield depends on each investor’s personal tax situation.

Clarification: In our pricing/ROI model we assume an effective local corporate tax of ~20% (after deducting interest, depreciation and eligible costs). Profits can flow tax-free to the Dutch holding (subject to PSD conditions), where the participation exemption applies. When the Dutch holding distributes dividends to investors, Dutch dividend withholding tax (currently 15%) may apply, often reduced or reclaimable under applicable tax treaties and depending on investor jurisdiction and profile. 
 

Compliance note: Anti-abuse and substance rules apply in both Portugal and the Netherlands. Genuine business purpose, real decision-making at the holding, and arm’s-length pricing are required to secure 0% EU WHT and Dutch exemptions.
 

Commitment to Fair Compensation and Local Contributions

We prioritize people at every level. Our local teams, who bring each stay to life, earn above-average wages with a guaranteed minimum of €20 net per hour, regardless of regional tax rates. This standard applies to both full-time and part-time employees, as well as freelancers, ensuring fair pay based on their rates but never below this threshold. We fulfill all required local taxes and social contributions on these wages, fostering strong communities and ensuring everyone at Rawness thrives.
 

The Abundance We Create

This strategy unlocks greater potential: Amplified funding for regeneration through the Resilience & Impact allocation (≈10% of net profits: 40% of retained in Phase 1; 20% of retained in Phase 2), equitable net wages for our teams, affordable offerings for guests, and tangible benefits for ecosystems and communities. Join us in this journey; real transformation begins with purposeful choices that fuel grassroots innovation and equitable work.
 

What this means for ROI on our site

• Our published ROI figures are after local effective corporate tax (~20%) and before any personal withholding at the Dutch holding level.

• The Rental Price Calculation Formula calibrates pricing so that 50% occupancy pays a 5% dividend, and the expected ROI curve (with realistic High→Mid→Low filling) rises steeply as occupancy increases.

• For investors subject to Dutch dividend withholding on payouts from the holding, treaty relief/credit may reduce the 15% to a lower effective rate; many corporate/international investors can offset or reclaim this depending on their situation.
   

Quick summary (for diligence)

• Local SPV/OpCo pays tax on profit after interest & depreciation → effective ≈20%.

• EU Parent–Subsidiary Directive can allow 0% WHT on dividends from the local SPV/OpCo to the Dutch holding if conditions are met (shareholding & substance). 

• Dutch participation exemption: dividends received by the NL holding from qualifying participations are exempt from Dutch CIT. 

• Dutch dividend WHT (generally 15%) may apply on outbound dividends from the holding to individual investors, often reduced or creditable under treaties.
   

Disclaimer:
This page is informational and reflects our understanding of current rules (EU PSD, Dutch participation exemption, treaty relief). It is not tax advice. Tax outcomes depend on investor profile and jurisdiction. Investors should seek independent advice; our shareholder trust agreements govern rights and processes.