Netherlands: Draft bill changes to fiscal and exempt investment institution, definition of taxable mutual fund

The Dutch Ministry of Finance launched an internet consultation on a bill containing a number of changes.

The Dutch Ministry of Finance launched an internet consultation on a draft bill

The Dutch Ministry of Finance launched an internet consultation on a bill containing changes to the fiscal and the exempt investment institution, and a change in the definition of a taxable mutual fund.


The government on 15 December 2022 announced the following measures:

  • Fiscal investment institutions (fiscal beleggingsinstellingen—FBIs) will no longer be allowed to directly invest in property (as of 1 January 2025).
  • Only investment institutions that have a license from and fall under the supervision of the Netherlands Authority for the Financial Markets and the Dutch Central Bank will qualify as a exempt investment institutions (vrijgestelde beleggingsinstellingen—VBIs) (as of 1 January 2024). In other words: the VBI regime will be eliminated for family-held VBIs.
  • The conditions governing (open) mutual funds will be amended (as of 1 January 2024).

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The draft bill contains accompanying measures to avoid the (immediate) levying of corporate income tax, individual (personal) income tax and real estate transfer tax as a result of those measures. The accompanying measures include:

  • Changes to FBI regime
    • Changes to corporate income tax
    • Temporary real estate transfer tax exemption in connection with changes to FBI regime
  • Changes to the independently taxable mutual fund (fonds voor gemene rekening—FGR)
    • Changes to corporate income tax
    • Tax consequences of changes in FGR definition and associated facilities
  • Changes to VBI regime

Next steps

The bill under review in the internet consultation is a draft bill. The final bill will probably be presented to the Lower House of Parliament on Budget Day 2023; some aspects of it may then have been amended as a result of the consultation now in progress. The bill will then work its way through the normal legislative process in the Lower and Upper Houses of Parliament. Changes may still be made to the bill during this process.

Read a March 2023 report prepared by the KPMG member firm in the Netherlands


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