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An overview by Borgen Tax, Taxand Netherlands
The Netherlands has recently updated its fund tax rules through the new ‘Fondsenbesluit 2025’, which clarifies when a vehicle qualifies as a Fund for Joint Account (FGR) or is treated as a transparent fund.
The key change is the removal of the old consent requirement for transferring units: an FGR must now meet the definition of an investment fund or UCITS-type fund under the Wft and must have tradable units, otherwise it is treated as an “inkoopfonds” and remains transparent. The decision also provides guidance on what counts as investing rather than running a business, the treatment of family-only funds, how the FGR and transparent-entity rules interact, and how the rules align with the reverse-hybrid regime. A transitional regime allows some existing transparent funds to restructure if they wish to stay transparent under the new definition.
Tax experts from our Dutch member firm Borgen Tax have published a more detailed overview of the new rules here.
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