Quoted: The new Dutch entity tax classification rules

Publication

05-02-2025

5 minutes read

As of 1 January 2025, all Dutch and foreign partnerships are, as a main rule, classified as transparent for Dutch tax purposes, except when a partnership should be considered a fund for joint account (FGR). In addition, also the tax classification rules applicable to FGRs were amended as of 1 January 2025 as well as those applicable to entities formed under foreign law.

Key insights

New tax entity classification rules apply as of 2025.

As a main rule Dutch and foreign partnerships classify as tax transparent.

Unless such partnership should be considered an FGR.

For new to be established investment funds, it is recommended to include a redemption mechanism into the fund documentation to classify as a tax transparent redemption fund.

Private Equity & Funds

Investment Management Fund Structuring & Formation Real Estate Investment Management Tax

This first 2025 edition of Quoted is an update of our Quoted of June 2024, which edition also focused on the pre-2025 rules and the grandfathering rules that applied during 2024.

This edition solely focuses on the current rules and addresses the new tax classification rules for the Dutch limited partnership (CV), the FGR and foreign entities. Furthermore, it focuses on when a limited partnership can qualify as a non-transparent FGR.