The new Dutch entity tax classification rules – update

Publication

26-06-2025

5 minutes read

On 1 January 2025, the new Dutch tax classification framework 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 be considered a fund for joint account (FGR). Also the tax classification rules applicable to FGRs were amended as from 1 January 2025 as well as those applicable to entities formed under foreign law.

Key insights

Most Dutch and foreign partnerships are tax-transparent unless they qualify as an FGR

FGR and foreign entity classification rules were also updated

Tax Investment Management Fund Finance

Early 2025, a public consultation was launched to obtain input from the market on the issues and uncertainties on the new rules applicable to FGRs. In April 2025, a Q&A document addressing a number of practical questions was published by the Dutch Ministry of Finance. Subsequently, in June 2025, the Dutch State Secretary for Finance issued a letter on the outcome of the public consultation, identifying three main bottle necks in the current rules – two of those will be further investigated and legislative changes may be expected.

This edition of Quoted is an update of our Quoted of February 2025. It gives an overview of the current (2025) Dutch entity classification rules and addresses the new insights and developments in relation thereto.