The new Dutch entity classification rules: what will change as per 2025?

As from 2025, all (existing) Dutch partnerships (CVs) will be classified as transparent for Dutch tax purposes. In addition, as from 2025, the tax classification rules applicable to Dutch funds for joint account (FGRs) are amended.
Finally, the Dutch tax classification rules for foreign entities will also change per that date.

These new tax classification rules could result in tax becoming due as a result of the transition from a non-transparent to a tax transparent classification. In order to mitigate this tax exposure for both entities concerned as well as their participants, during 2024 transitional law provides, subject to meeting certain conditions, for several facilities (e.g., roll-over facilities).