NETHERLANDS Trends and Developments Contributed by: Frans Sonneveldt, Mike Vrijmoed and Bianca de Kroon, Forvis Mazars NV
eign tax liability in the Netherlands was abolished as of 1 January 2025, with transitional arrangements for existing cases. For high-net-worth individuals, this was the most significant benefit of the ex-pat facility. Although tax considerations often play a role in these decisions, they are rarely the sole driver. Just as much as tax considerations, decision-making is frequently influenced by: • lifestyle considerations; • political stability; • education; • family circumstances; and • succession planning. As mobility increases, so does complexity. Questions around tax residency, inheritance tax, business suc - cession and cross-border wealth structures require careful planning long before any move actually takes place. Family offices The increasing complexity of family wealth has led to a growing professionalisation of family offices. Families often hold a mix of operating businesses, investment portfolios, private equity interests and international real estate investments. Managing those assets has become materially more complex due to increasing reporting obligations, governance requirements and cross-border considerations. As a result, family offices are increasingly asked to perform a broader role. Beyond investment oversight, they are becoming central co-ordination platforms for governance, succession planning, philanthropy and next-generation education. In our experience, many families are moving away from informal arrangements towards more institutionalised governance models. Corporate Income Tax and Dividend Withholding Tax For business owners and shareholders, there are several essential developments in corporate income tax and dividend tax. A noteworthy change in Dutch tax law is the abolition of the open limited partner - ship ( open commanditaire vennootschapor CV ) sta - tus, effective 1 January 2025. This modification sig -
nificantly impacted numerous investment structures. Open CVs have lost their corporate tax status and become transparent for tax purposes. The open CV structure has been widely utilised in privacy-oriented arrangements. Similar changes also apply to open mutual family funds ( open fonds voor gemene rekening ) and to foreign partnerships. The dividend tax rate in the Netherlands remains at 15%, with a general full exemption for intra-group dividends. However, it is crucial to be aware of anti- abuse measures, particularly relevant for foreign hold - ing companies with stakes in Dutch entities. These measures can pose significant challenges, especially for privately held foreign holdings that struggle to meet the requisite substance requirements. The substance criteria include, among others: • a minimum of EUR100,000 in annual payroll costs, which must be directly related to the activities involving participation in the Dutch company; and • the holding company must have an appropriate office space at its disposal. These requirements are designed to ensure that the holding company has a genuine economic presence in its jurisdiction, rather than existing solely for tax purposes. Failure to meet these criteria can result in the denial of tax benefits and potential additional tax liabilities. Philanthropy and Purpose-Driven Wealth In practice, increased focus on philanthropy and impact has been noticeable. Many families are no long - er discussing only how wealth should be preserved, but also what purpose that wealth should serve. This is reflected in growing interest in charitable founda - tions, ANBI structures, impact investments and struc - tured gifting programmes. Philanthropy is increasingly integrated into broader family governance and suc - cession discussions. Particularly among younger gen - erations, financial returns are often viewed as only one measure of success. Questions surrounding steward - ship, sustainability and societal impact are becoming increasingly important.
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