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Netherlands: Guidance on application of new framework for determining tax characterization of foreign legal forms

New framework will become effective January 1, 2025

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December 11, 2024

A Dutch tax authorities’ knowledge group published its position on the German Sondervermögen and the funds decree, which contains the new framework for determining the tax characterization of foreign mutual funds effective January 1, 2025, on December 4 and 6, 2024 respectively. 

The position means that as of January 1, 2025, German Sondervermögen will in principle all be regarded as non-transparent for Dutch tax purposes.

  • Under current law, German Sondervermögen with only one unitholder are regarded as tax transparent, and if that unitholder is an exempt entity (for example an exempt government body or qualifying pension fund), then it will not be subject to corporate income tax in the Netherlands or it will be entitled to a dividend tax refund if it invests in Dutch shares.
  • According to the knowledge group position, this will change as of January 1, 2025.
  • A reservation is made for Sondervermögen that have taken advantage of the “Transparenzoption,” under which the income of the fund is not taxed at the fund but at its unitholders, but it is not clear whether this option will (automatically) mean that these funds are transparent for Dutch tax purposes.

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

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