New partnership rules set to take effect in 2025 may subject regulated funds using tax-transparent Dutch Commanditaire Vennootschap (CV) structures to Dutch corporate income tax (CIT) and dividend withholding tax (DWT). The CV is a frequently used partnership vehicle to structure regulated funds and associated feeder/investment entities.
Per 1 January 2023, the Dutch RETT (real estate transfer tax) will increase from 8% to 10.4%. Transactions that close after 31 December 2022 will therefore be subject to a 2.4% higher transfer tax.
It may be possible to avoid this by applying a Provisional Closing Scheme (Groninger akte structuur). This essentially means that the
In addition to existing global, European, and national initiatives against tax avoidance, the Dutch Ministry of Finance earlier this year announced the introduction of two additional substance requirements in a policy letter on tackling tax avoidance and tax evasion. The additional substance requirements would apply to Dutch resident entities to obtain an advance tax