Fund taxation in Holland

In Holland a professional investor may use various vehicles on the funds market. UCITS (Undertakings for Collective Investments in Transferable Securities) and AIF (Alternative Investment Fund) are the most common vehicles that can be marketed in the European Union.

Taxation is among the main considerations in investment fund set-up. In this respect Holland is a very attractive jurisdiction.

If you need further information on the taxation of investment funds in Holland, please, contact our advisors in company formation.

Tax treatment of investment funds (IFs) in Holland

Dutch IFs can qualify for one of three tax categories:

1. tax-exempt IFs;
2. fiscal IFs;
3. tax-transparent IFs.

Each category brings particular tax advantages.

Tax exempt Dutch IFs

Under particular conditions hedge funds and open-end retail funds may be exempt from withholding and corporate income taxes. A main requirement that needs to be fulfilled is the issue of a license by the National Authority for the Financial Markets (AFM).

Fiscal IFs taxation in Holland

Fiscal IFs are not subject to corporate income tax. A withholding tax of 15% applies to the dividends distribution, unless provided otherwise by a treaty for double tax avoidance signed by Holland. In order to receive such tax treatment, the fund has to be incorporated as a public or private Dutch company with limited liability.

Our local registration agents can assist foreign investors in establishing Dutch investment funds.

Tax-transparent IFs in Holland

For the purposes of taxation, a Dutch IF may be deemed transparent if:

1.  the IF is not considered a legal entity with respect to withholding and corporate income tax;
2. the IF is a closed-end fund for mutual account (in Dutch : fonds voor gemene rekening, FGR);
3. the IF or its managers do not have a registered Dutch seat;
4. the IF is not licensed by the National Authority for the Financial Markets.

If you need further information regarding the tax requirements for Dutch investment funds, please, contact us

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Sources

• OECD - transfer pricing and international tax guidance
• Wet op de vennootschapsbelasting 1969 (wetten.overheid.nl)
• AFM - capital markets and prospectus supervision
• Officiele bekendmakingen - Dutch official government gazette
• PwC Netherlands - tax insights and publications
• Hoge Raad 2025, interest deduction limits (art. 10a Vpb) (ECLI:NL:HR:2025:1250)
• Hoge Raad 2025, fiscal unity and loss set-off (ECLI:NL:HR:2025:1957)
• De Brauw Blackstone Westbroek - legal insights
• Court of Justice EU, the Danish beneficial ownership cases on abuse (C-116/16)
• Belastingdienst - corporate income tax rates (19% up to EUR 200,000 and 25.8% above)