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Introduction Starting 1 January 2025, new qualification rules will apply for determining the Dutch tax status of foreign legal forms.  Under these new rules, Dutch limited partnerships (CVs) and foreign limited partnerships (LPs) will generally be classified as transparent for Dutch tax purposes, unless they also qualify as a fund for joint account (FGR) in which case the FGR qualification rules take precedence over the general classification rules (priority rule). Under the new rules, FGRs can both be tax-transparent and non-transparent depending on the exact characteristics. The new 2025 FGR qualification rules could result in existing foreign LPs transitioning from opaque  for Dutch tax purposes to a tax transparent status, which could result in Dutch tax becoming due. On the other hand, LPs currently treated as tax-transparent and that can be designated as 'investment funds' may transition to a non-transparent FGR status from 1 January 2025. This transition depends on whether the LP possesses the main characteristics of an FGR.  It is expected that many investment CVs and investment LPs could be reclassified as non-transparent FGRs based on the new rules. Although some criteria remain uncertain, there is a one-year transition period to make the necessary changes to the fund documentation to maintain the current tax-transparent status. Required Action Before 1 January 2025 To maintain tax transparency, action must be taken before 1 January 2025.  Under the new rules, LPs that do not conduct a business enterprise but perform investment activities for Dutch tax purposes can be considered an FGR from 2025.  The Dutch tax classification rules for FGRs also change as of 1 January 2025.  An FGR is tax-transparent unless it meets all the following criteria:It is an 'investment fund' (e.g., an AIF) or a 'fund for collective investment in transferable securities' (UCITS) under the Dutch Financial Supervision Act (Wft). It is established for collective investments (with at least two investors).  For example, a German Sondervermögen with only one investor will not qualify as an FGR and will automatically be classified as opaque for Dutch tax purposes. It follows a strategy classified as 'normal' portfolio management. The participations are embodied by 'transferable participation units,' which are not considered transferable if they are only (quasi) transferable to the fund through redemption. It is uncertain what constitutes 'transferable participation units'. It seems that even a registration in an investors register may qualify as such. Redemption Fund: Non-Transferable Participation Units If the transfer of participations can only take place to the fund itself (the so-called redemption fund), the participations are considered non-transferable for purpose of the qualification rules. The fund is then not considered an FGR and therefore qualifies as tax transparent. In order to enjoy this treatment, the fund's terms must indicate that a (conditional) redemption right of the participation holder applies.  Even if the fund holds the participations in its portfolio after (re)purchase to reissue the units, they remain non-trans­fer­able, and the fund is not considered an FGR.  This also applies if the participation holder resells their participation unit to the fund, while the fund immediately reissues that unit to a third party designated by the participation holder. Redemption Fund and Secondary Trading It occurs that a fund, in addition to the redemption obligation in the fund's terms, includes provisions under which, under certain conditions, the sale of participation units to a third party is possible.  This is also known as secondary trading and often relates to the circumstance that the fund (or the manager) does not have sufficient liquid assets to redeem the participation units, for example, because the fund's assets are invested in (illiquid) real estate.  If the fund (or the manager) is a party to the agreement between the old and the new participation holder and the financial settlement of the transfer of the participation units actually takes place through the fund (or the manager), it remains a redemption fund.  This is still the case if, in addition to the financial settlement through the fund (or the manager), a premium or discount settlement takes place between the buyer and the seller. Conditions for Secondary Trading In all cases of secondary trading where the financial settlement of the transfer of the participation units does not actually take place through the fund (or the manager), the fund can only be considered a redemption fund if both of the following conditions are met:The fund's terms or the prospectus state that the transfer by a participation holder to a third party is deemed to take place through the fund (or the manager), andThe fund (or the manager) charges a fee to the selling participation holder for the presumed redemption of the participation unit(s) or to the buyer for the presumed issuance of the participation unit(s). Transitional Provisions The Dutch government has confirmed that investment CVs and investment LPs, and funds in general, currently transparent for Dutch tax purposes will have the opportunity to amend their limited partnership agreements (LPA) in 2025 to meet the criteria of a Redemption Fund.  To qualify for this transitional provision, such CVs, LPs and other funds must be able to demonstrate that the intention to amend their fund terms (including the LP agreement) to meet the conditions of a Redemption Fund already existed in 2024. Required Action We recommend that CVs and LPs (and funds in general) affected by these changes inform their investors about the upcoming changes and also that the intention exists to amend the LP agreement (or fund terms) on the relevant points before 1 January 2025 to take advantage of this transitional period effectively.  The LP agreement or fund's terms must then be amended by the end of 2025 to ensure that the fund qualifies as a Redemption Fund, thereby maintaining tax transparency. If no action is taken, as of 1 January 2025, there may be independent tax liability for foreign funds regarding the (real estate) assets they hold, and investors in that fund may be deemed to have sold their share in the (real estate) assets at fair market value to the fund as of 1 January 2025 (a tax settlement moment).  Additionally, dividends paid by entities established in the Netherlands may be subject to a different tax.  In some cases, this could attract a withholding tax rate of 25.8%.  If you would like further advice on the impact of the new rules and the necessary actions, please contact your regular advisor or CMS Netherlands. Contact Should you have any questions regarding this publication, please contact us.

Current situation and problem The waiver gain exemption within Dutch corporate income tax (Vpb) is designed to relieve companies in financial difficulties. This exemption ensures that benefits resulting from the surrender by creditors of irrecoverable receivables are, under certain conditions, not included in the taxable profit of the debtor. This prevents companies from experiencing additional tax burden due to debt forgiveness and deters creditors from cancelling debts. However, with the introduction of new loss relief rules from 1 January 2022, a problem has arisen. These rules limit loss relief in Vpb: losses up to an amount of €1 million are fully creditable against taxable profits each year, but above that amount, the loss is only creditable against 50% of the remaining taxable profits. This has led to situations where, despite debt cancellation, companies still have to pay corporate tax because their losses cannot be fully offset. This can be an obstacle for companies trying to recover from financial difficulties. Proposed amendments The Tax Plan 2025 introduces a number of changes to address this issue and bring the debt forgiveness profit exemption more in line with the new loss relief rules. The main change is that benefits from debt forgiveness will not be included in the taxable profit of the debtor if these benefits exceed the loss incurred in the same year and the losses still to be set off from previous years. For companies with more than €1 million in offsetable losses, the remission profit is fully exempted to the extent that it exceeds the losses in the year of remission. The offsetable losses are then reduced by the amount of the exempted waiver gain. This means that companies with significant losses will not have to pay corporate income tax on remission gains that exceed their losses, giving them more room to recover financially. Case study To illustrate the implications of this proposed change, here is an example of how the proposed scheme works out: Example: current situation Suppose X BV owes €6 million to its suppliers. These debt receivables are non-recoverable rights. The suppliers waive these receivables. In the year of renunciation, X BV suffers a loss of €0.5 million and has outstanding losses from previous years worth €4 million. Under the current rules, the waiver gain is €6 million. The remission profit exemption only applies to the part that exceeds the loss in the year of remission and the losses from previous years that can still be set off.  This means that X BV has a waiver gain exemption of €1.5 million (€6 million - €0.5 million - €4 million). The taxable profit is then €4 million (€6 million - €1.5 million - €0.5 million). Due to the restriction on loss offset, X BV can only offset €2.5 million in losses (€1 million + 50% of €3 million), resulting in a taxable amount of €1.5 million and therefore a tax liability. Example: proposed measure Under the proposed measure, for situations with offsetable losses in excess of €1 million, the waiver gain will be fully exempt to the extent that it exceeds the losses in the year of waiver. In this example, this means that X BV has a waiver gain exemption of €5.5 million (€6 million - €0.5 million). The taxable profit and taxable amount are both nil because the non-exempt waiver gain (€0.5 million) cancels out against the loss in the year of remission (€0.5 million). No tax liability arises. Conclusion The proposed change to the waiver gain exemption within the 2025 Tax Plan aims to resolve bottlenecks created by the new loss relief rules in force since January 2022. The changes will prevent companies already in financial difficulty from experiencing additional tax burdens due to loss relief restrictions. The changes ensure that companies with significant losses above €1 million will not have to pay corporate income tax on loss relief gains that exceed their losses. This gives companies more room to recover financially without additional tax burden. In essence, these changes contribute to a fairer and more effective tax system that supports business recovery and growth. It prevents unnecessary bankruptcies and promotes economic stability by giving companies breathing space when they need it most.

On Tuesday 17 September 2024, the State Secretary of Finance presented the 2025 Dutch Tax Plan. We discuss the proposals we consider most relevant for the real estate sector.

On Tuesday 19 September 2023 the Dutch State Secretary for Finance published the 2024 Tax Plan and related legislative tax proposals. This newsflash primarily discusses the proposals that we consider most relevant for (international) companies. Dividend stripping Dividend stripping is the practice of splitting the economic interest in and legal title to dividends in order to obtain a dividend withholding tax advantage. The 2024 Tax Plan proses to improve the possibilities to combat dividend stripping through the following two separate measures:The introduction of a record date for recording the beneficiary of the dividends and the underlying credits, refunds or reductions of dividend withholding tax; andImproving the burden of proof for tax authorities in cases of suspected dividend stripping. The later measures only apply if the underlying tax amount exceeds EUR 1,000. Dutch tax classification rules for (foreign) entities A new regime for the classification of (foreign) entities for Dutch tax purposes is proposed as of 2025. The regime aims at reducing (hybrid) mismatches between the Netherlands and other jurisdictions and will include the following key elements:the codification of the current tax classification method for foreign entities;the current tax classification method for foreign entities will be supplemented by the 'fixed'-method and the 'sym­met­ric­al'-meth­od for foreign entities that do not have a comparable Dutch legal form, whereby:the 'fixed'-method entails that if an entity established under foreign law is resides in the Netherlands, the entity will always be regarded as tax opaque; andthe ''sym­met­ric­al'-meth­od means that if an entity established under foreign law (with a shareholder relationship with a Dutch resident taxpayer) and that entity does not reside in the Netherlands, the Dutch qualification of the entity will follow the qualification of its country of residence; andthe so-called unanimous consent requirement (toes­tem­mingsvereiste) will be abolished and all Dutch limited partnerships (CV), including the open limited partnerships (open CV) that currently is regarded as tax opaque, will qualify as tax transparent (except for reverse hybrid structures). The change in the tax classification of the open CV from tax opaque to tax transparent will trigger a final settlement which may result in a tax liability. Facilities are proposed to allow for a tax neutral restructuring. The impact of this proposal needs to be assessed as soon as possible with a viewing to benefitting from the special restructuring facilities in 2024. Changes to the tax classification of Dutch mutual funds (fonds voor gemene rekening or FGR) Under the current rules, the FGR can be structured as tax transparent or tax opaque for Dutch tax purposes. An FGR qualifies as tax transparent it the rules relating to the transfer of units are structured according to:the unanimous consent variant –units are only transferable with the prior unanimous consent of all other unitholders. The redemption variant – units can only be redeemed and issued by the FGR, i.e. only be transferred to the fund itself. All other FGRs are currently treated as tax opaque for Dutch tax purposes. Under the proposed new rules, an FGR will only qualify as tax opaque for Dutch tax purposes if the FGR is regulated under the Dutch Financial Supervision Act and the participation units are freely transferable. In this respect, the units will not be considered freely transferable if the units can only be redeemed and issued by the FGR itself. All other FGR's will be treated as tax transparent as of 2025. The change in tax classification from tax opaque to tax transparent will trigger a deemed disposal of the assets and liabilities of the FGR which may result in a Dutch corporate income tax liability. In order to give taxpayers the opportunity to restructure in a tax neutral manner in preparation for the change in the tax classification of FGRs, several facilities are offered. We would advise FGRs that currently qualify as tax opaque and are affected by this proposal to take advantage of the restructuring opportunities in 2024 before the proposed changes take effect from 2025. VBI regime It is proposed that the Dutch exempt investment institution regime (VBI regime) will be limited to entities that are regulated under the Dutch Financial Supervision Act as of 2025. This will eliminate the current possibility of using this exempt regime for Dutch corporate income tax purposes for the investment in private assets. FBI regime It is proposed that Dutch fiscal investment institutions (FBI) will be prohibited from directly owning Dutch real estate. Any FBI directly owning Dutch real estate as of 2025 will be subject to corporate income tax. Any FBI affected by the change in legislation and wishing to avoid such tax obligations will have to complete a necessary restructuring in 2024. During this period, a real estate transfer tax exemption will be introduced for restructurings by FBI to divest any prohibited assets or subsidiaries. Real estate transfer tax on share deals / concurrence exemption From 2025 the so-called concurrence exemption for the acquisition of shares in a real estate company will be abolished (concurrence between VAT and real estate transfer tax). As a result, the indirect acquisition of newly developed real estate will be subject to real estate transfer tax at the new rate of 4%, calculated on the fair market value of the new building or buildings. However, the concurrence exemption remains available if during the first 2 years after the share acquisition the underlying real estate is used for activities that entitle the owner (entity) to recover at least 90% of the VAT. With respect to asset deals, no changes are proposed concerning the concurrence exemption from real estate transfer tax. Environmental measures A number of environmental measures are proposed, the most important of which are an increase in the carbon emissions tax from 2024 and the extension of existing tax incentives (albeit at reduced percentages). In addition, it has been stated that all relevant tax breaks for the 'fossil industry' and their effectiveness have been identified during the last government period. However, due to the caretaker status of the current cabinet, any decisions regarding potential adjustments to these tax incentives will be deferred to the next cabinet. Other tax changes as per 2024 Box 2 tax rates for income from substantial interest As per 2024, the flat rate of 26.9% will be replaced by a general rate of 31%, with a step-up rate of 24.5% applying to the first EUR 67,000 of income from substantial interest. In short, a substantial interest is held if a private shareholder owns 5% of a company (or 5% of a special class of shares). Box 3 – income from savings and investments From 2024, the box 3 tax rate (which applies to income from passive investments) will increase from 32% to 34%. In addition, further guidance has been published on a number of points to determine the relevant tax base for box 3. The introduction of a new box 3 regime based on actual income will be delayed from 2026 to 2027. 30% ruling limited to maximum public sector salary Employees recruited from abroad who have specific expertise that is rare in the Netherlands are offered a favourable tax regime under which 30% of their gross salary can be paid as a net remuneration. From 2024, the application of the 30% ruling will be limited to the maximum salary for the public sector (EUR 223,000 in 2023). For existing 30% rulings with an expiry date after 1 January 2024, a transitional regime will be introduced under which the limit will apply from 1 January 2026. The way forward In the coming months, the 2024 Tax Plan will be discussed in both chambers of Dutch parliament. This means that the proposed measures are subject to change. We will keep you informed of any relevant changes. Please do not hesitate to contact us if case you have any questions.

On 22 February 2018, the European Court of Justice (ECJ) issued its decision in the joined Cases C‑398/16 and C-399/16. The decision regards the compatibility of the Dutch fiscal unity regime in the Dutch Corporate Income Tax Act with the freedom of establishment in the Treaty on the Functioning of the European Union. The former case (C-398/16) concerned a Dutch company (DutchCo) which received a loan from its Swedish parent company (TopCo), loan 1, which was used to make a capital contribution in an Italian subsidiary (ItalianSub). ItalianSub used this capital contribution to acquire part of the listed shares in an Italian group entity (SpA). The non-listed shares in SpA were held by TopCo. Subsequently, DutchCo directly acquired the remaining part of the listed shares held by third parties in SpA after the public bid. The purchase price of this shares were also financed by DutchCo with a loan obtained from TopCo (loan 2). Case C-398/16 dealt with compatibility of the fiscal unity rules during the tax year 2004. Today (3 March 2023), the Supreme Court issued a decision in case 21/00299 that addresses the Dutch tax treatment of DutchCo in later tax years. The Dutch tax authorities again tried to deny the tax deductibility of the interest costs in respect of both loan 1 and loan 2, invoking the anti-base erosion rules of section 10a of the Dutch Corporate Income Tax Act (CITA). Section 10a CITA stipulates that interest on debt is not deductible if such debt is due to an affiliated entity where that debt is related to (inter alia):a capital contribution to an affiliated entity (like here DutchCo contributed to ItalianSub), orthe acquisition or extension of an interest in an entity that is an affiliated entity after such acquisition or extension (like here DutchCo also acquired shares in the affiliated SpA). An exception to the non-de­duct­ib­il­ity pursuant to Section 10a applies if the taxpayer makes it plausible that both the debt and the related transaction are predominantly based on business considerations. For purpose of these rules, also loans entered into under arm's length conditions can be treated as not being based on business considerations. In today's decision the Supreme Court considers that with regard to the examination of the motives for the relevant transactions (the acquisition of the SpA shares and the contribution to ItalianSub) and debt (loan 1 and loan 2), it is to be understood that only the considerations underlying those transactions and debt are relevant. In that examination, it is important that it is inherent in the system of the CITA that the taxpayer in principle has freedom of choice in the method of financing a company in which he participates. To the extent that the anti-base erosion rules infringe this freedom of choice by not allowing a tax-deduction of interest owed, these rules must be interpreted restrictively. The Supreme Court also considers that in addition to the freedom of choice as regards financing, a taxpayer, and in the present case a group of companies, has the freedom to locate its economic interests and (financial) resources in a company residing in the Netherlands (i.e., to 'use' a Dutch resident company) even if that choice is determined by tax considerations. The anti-base erosion rules are not aimed at limiting this second freedom. According to the Supreme Court that freedom applies to the set-up of a group, meaning that no provision of the CITA or any principle underlying it contains norms as to where within the group activities are placed and where holding and intermediary activities or financing activities are carried out. For purpose of the anti-base erosion rules an external acquisition – like here the direct acquisition by DutchCo of shares in SpA held by third parties – should in the vast majority of cases be considered being based on sound business considerations. The Supreme Court considers that a debt is in principle predominantly based on business considerations if the funds used for granting the loan have not been diverted from another party via the actual lender of record. This also applies, according to the Supreme Court and contrary to the Dutch tax authorities' view, to a debt related to a transaction other than an external acquisition, which falls within the scope of section 10a of the CITA- such as the capital contribution by DutchCo to ItalianSub - if predominantly business considerations underlie the other transaction. The Supreme Court decides that from the parliamentary history of Section 10a it follows that a debt from an affiliated party may be predominantly based on business considerations if the affiliated lender has sufficient substance and, through its financing activities, performs an active financing function within the group of entities affiliated with the Dutch taxpayer (hereinafter: financial pivot function). According to the court it is consistent with fulfilling such a financial pivot function, and thus an arm's length, non-tax consideration, that this financing entity raises funds from group entities and from third parties and then uses these funds to make loans to other group entities (such as the taxpayer). In other words, in principle, a debt is predominantly based on commercial considerations if the affiliated entity from which the taxpayer obtained the debt performs financing activities in such a way that it thereby performs a pivotal financial function. Under such circumstances, funds cannot be said to have been diverted in a non-busi­ness-like way. This is not different if the affiliated lender obtained the funds used for that loan from another entity belonging to the same group. On the contrary, according to the court, performing a pivotal financial function within the group will often give rise to this. Therefore, if the affiliated entity performs a pivotal financial function, successful reliance on the rebuttal mechanism of Section 10a will not require to establish a link between the funds outstanding - from time to time - in the form of loans granted (the asset side of the lender's balance sheet) and the funds raised - from time to time - in the form of loans taken up and deposits obtained (the liability side of the lender's balance sheet). When assessing whether an affiliated entity performs a pivotal financial function through its financing activities, the circumstances of the case must be considered in context. Central to this is that the entity or independent business unit performs an active financing function within the group of entities related to it. Furthermore, the entity or independent business unit in question must be mainly engaged in carrying out financial transactions on behalf of entities belonging to the group, such as borrowing and lending money and managing excess group resources. Furthermore, that (business unit of the) entity will have to be independent in the day-to-day conduct of its business, including the management of outstanding funds, and for that purpose it will have to have sufficient and competent staff and, if it is an independent business unit, its own administration. If that (business division of the) entity is bound by a centrally determined strategy for the group, this mere circumstance does not prevent it from being independent. Finally, the Supreme Court also addressed the tax authorities' position that if deductibility of the interest costs can not be based on Section 10a, that such deductibility would have to be refused based on abuse of law considerations. According to the court this position, which has been defended by the tax authorities ever since these anti-base erosion rules were introduced in 1996, is not possible. The prevailing doctrine is that two cumulative conditions must be met for abuse of law (fraus legis) to apply. First, tax avoidance must have been the overriding motive for carrying out the transaction(s), the motive requirement. This is a subjective requirement. Second, the act(s) must be contrary to the purpose and spirit of the law, also known as the norm requirement. This is an objective requirement. If interest costs are tax-deductible on the ground that the taxpayer has made it plausible that the loan and the related transaction are predominantly based on business considerations, this excludes the fulfilment of the motive requirement for application of abuse of law doctrine in respect of this same loan and transaction, according to the Supreme Court in today's decision. This means that the deduction of interest in that case cannot still be refused on the basis of the Dutch tax authorities reliance on this doctrine. Conclusion From today's decision it follows that:as decided before, the CITA does not prevent an international group of organizing its group in a certain way (including the use of a Dutch entity), unless specific rules apply;as decided before, the CITA does not require a Dutch taxpayer to be financed in a certain manner or to finance specific transactions in a certain manner, unless specific rules apply;if a transaction is based on business considerations and a Dutch taxpayer obtains a loan from an affiliated party that performs a pivotal financial function within the group, such taxpayer should be able to successfully apply the rebuttal rule under Section 10a, causing the tax-de­duct­ib­il­ity of the interest costs not to be restricted based on the anti-base erosion rules;if a Dutch taxpayer successfully applies the rebuttal rule under the anti-base erosion rules, there is no room for the Dutch tax authorities to deny the tax deductibility of the interest costs based on the general abuse of law doctrine. Clearly, today's decision is welcomed by many taxpayers. Obviously, other elements of the CITA and other Dutch tax laws need to be considered before any decision about the structuring of a transaction, and its financing, can be taken.

ESG: Environmental, Social & Governance

Over a relatively short period of time, the implementation of ESG (environmental, social and governance) aspects in commerce has grown to become a strategic priority at management level. While the substance of ESG is likely to evolve in the coming years, the underlying impulse for businesses to make a social contribution, and not just an economic one, is here to stay. In essence, it is about maintaining and reinforcing the social licence of a business to operate in a rapidly changing world. As a result, ESG goes to the heart of every business. Future-looking companies Not all aspects of E, S and G are priorities for all companies. Companies will carefully have to weigh which ESG aspects they want to focus on. For that reason, it is instructive to observe organisations that approach ESG in a rigorous, strategy-driven, socially attuned way. McKinsey calls these organisations ‘for­ward-look­ing companies’. They make ESG intrinsic to their strategy by deliberately applying those ESG aspects that connect to the core of their business. Forward-looking companies also promote competition by standing out and using good corporate citizenship to contribute to finding solutions to existential challenges, such as climate change. Distinguishing role Whatever your company's ambition, you will always need to comply with the ESG regulations, including those on environmental legislation, labour-law issues and governance. But forward-looking companies take it one step further, and usually raise the bar by focusing on certain aspects of ESG in which they can play a leading or distinguishing role. Ideally, this will also motivate similar companies to take a comparable route when it comes to ESG. Roadmap to social profit This ESG special publication provides company lawyers a concise overview of the most important ESG regulations, as well as concrete tools to give managers better advice in the field of ESG. Various aspects and elements of a company will be discussed: from the distribution chain to commercial property, from sustainable financing issues to the desired level of diversity and inclusivity within the population, and from governance to ESG litigation.

On Tuesday 20 September 2022 the Dutch state secretaries for Finance published the 2023 Tax Plan and related legislative tax proposals. This newsflash discusses the proposals we consider most relevant...

Over the past two years, enterprises, governments and citizens have grappled with unparalleled technological evolution and new business models, as well as significant tax reforms, regulatory changes...

What’s next? In a world of ever-ac­cel­er­at­ing change, staying ahead of the curve and knowing what’s next for your business or sector is essential. At CMS, we see ourselves not only as your legal advisers but also as your business partners. We work together with you to not only resolve current issues but to anticipate future challenges and innovate to meet them. With our latest publication, CMS Next, our experts will regularly offer you insights into and fresh perspectives on a range of issues that businesses have to deal with – from ESG agendas to restructuring after the pandemic or facing the digital transformation. We will also share with you more about the work that we are doing for our clients, helping them innovate, grow and mitigate risk. To be able to provide you with the best support, we immerse ourselves in your world to understand your legal needs and challenges. However, it is equally important that you know who we are and how we can work with you. So, we invite you to meet our experts and catch a glimpse of what is happening inside CMS. Enjoy reading this publication, which we will update regularly with new content. CMS Executive Team

On Tuesday 21 September 2021 the Dutch state secretaries for Finance published the 2022 Tax Plan and related legislative tax proposals. This newsflash discusses the proposals we consider most relevant...

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