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Netherlands: Clarifications regarding tax classifications for Barbados, French, and Saudi entities

Tax classification of a Barbados society with restricted liability, a French common investment fund, and Saudi joint stock companies

July 23, 2026

The Dutch Tax Administration on June 5, 2026, and June 10, 2026, published clarifications regarding the Dutch tax classification of a Barbados society with restricted liability (SRL), a French common investment fund, and a Saudi joint stock company (JSC) and simplified joint stock company (SJSC).

  • Barbados society with restricted liability: The clarification published on June 5, 2026, confirms that, for Dutch corporate income tax (CIT), individual income tax, dividend withholding tax, and conditional withholding tax purposes, a Barbados SRL is comparable to a Dutch public limited company (NV) or private limited company (BV).
  • French common investment fund: The clarification published on June 10, 2026, states that a French common investment fund is not comparable to a Dutch legal form. However, the fund may be comparable to a Dutch mutual fund or a transparent fund depending on the relevant facts and circumstances, with the assessment reserved for the tax inspector.
  • Saudi joint stock companies: The Knowledge Group of the Dutch Tax Administration published a clarification on June 5, 2026, confirming that, for Dutch CIT, individual income tax, dividend withholding tax, and conditional withholding tax purposes, a Saudi JSC and SJSC are comparable to a Dutch NV or BV.


For more information, contact a KPMG tax professional in the Netherlands:

Paul te Boekhorst | teboekhorst.paul@kpmg.com

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