The Dutch entity tax classification rules (update)

Publication

05-02-2026

5 minutes read

On 1 January 2025, various new rules relating to the classification of (Dutch and foreign) entities for Dutch tax purposes entered into force. Dutch and foreign (limited) partnerships are now, as a main rule, classified as transparent for Dutch tax purposes, except when a (limited) partnership should (also) be considered a fund for joint account (FGR). Also the FGR definition was amended on 1 January 2025, as well as the tax classification framework for foreign entities.

Since 1 January 2025, there have been various developments regarding the definition of the FGR and the qualification of partnerships as FGR. New guidance and grandfathering rules have been introduced, and a draft legislative proposal was published for consultation in December 2025 in relation to further amendments to the FGR definition as per 1 January 2027.

This edition of Quoted is an update of our Quoted of October 2025. It covers the recent developments and provides an overview of the current state of play of the Dutch entity tax classificationrules.