Netherlands: Report to Parliament on investigation into REIT regime

Pros and cons of a new Dutch real estate investment trust (REIT) regime

Pros and cons of a new Dutch real estate investment trust (REIT) regime

The Secretary of Finance on June 7, 2024, sent a report to the lower house of Parliament on its investigation into the pros and cons of a new Dutch real estate investment trust (REIT) regime.

  • It was noted that the repeal of the real estate fiscal investment institution (FII) regime as of January 1, 2025, after which real estate investment companies investing in Dutch real estate will become subject to the regular Dutch corporate income tax regime instead of the 0% tax rate applicable to FIIs, puts the Netherlands at a disadvantage compared to other European countries that have a REIT regime.
  • The report states that advantages of a Dutch REIT regime are that the tax neutrality of a REIT regime stimulates collective investment in Dutch real estate (such as residential real estate) and that the Dutch investment climate as a whole may benefit. However, the design and implementation of a new REIT regime must carefully consider the budgetary losses that led to the repeal of the real estate FII regime.
  • The report presents some options that could be considered for a new REIT regime:
    • Tax REITs at a rate of 15% and provide relief of double taxation at the level of the REIT for the withholding tax charged to it and at the level of the (Dutch) participants in the REIT for the taxes charged at the level of REITs)
    • Exempt REITs from corporate income tax and dividend withholding tax, and levy tax on the fair market value of the real estate (a value assessed by the local municipality each year), whether or not in combination with a withholding tax on rent

Read a June 2024 report prepared by the KPMG member firm in the Netherlands



The KPMG name and logo are trademarks used under license by the independent member firms of the KPMG global organization. KPMG International Limited is a private English company limited by guarantee and does not provide services to clients. No member firm has any authority to obligate or bind KPMG International or any other member firm vis-à-vis third parties, nor does KPMG International have any such authority to obligate or bind any member firm. The information contained herein is of a general nature and is not intended to address the circumstances of any particular individual or entity. Although we endeavor to provide accurate and timely information, there can be no guarantee that such information is accurate as of the date it is received or that it will continue to be accurate in the future. No one should act on such information without appropriate professional advice after a thorough examination of the particular situation. For more information, contact KPMG's Federal Tax Legislative and Regulatory Services Group at: + 1 202 533 3712, 1801 K Street NW, Washington, DC 20006.