NETHERLANDS Trends and Developments Contributed by: Frans Sonneveldt, Mike Vrijmoed and Bianca de Kroon, Forvis Mazars NV
UBO Register and DAC6/7/8: Increasing Transparency
Outlook The wealth tax will be replaced by a system based on actual returns (although not entirely), the business succession facilities will continue to be refined and transparency obligations will continue to expand. At the same time, the great wealth transfer will accel - erate, bringing questions of governance, succession and purpose to the centre of family wealth planning. For families and their advisors, the conclusion follows from the trends described above. Structures should be stress-tested against legislative change rather than optimised solely for current rules, family governance should be documented before it is needed and suc - cession should be planned well before any transfer or relocation takes place.
Another clear trend is the shift from privacy towards transparency. Historically, wealth structures were often designed with confidentiality and asset protec - tion in mind. Today, increasing exchange of informa - tion between tax authorities and expanding disclosure requirements mean that transparency has become a central consideration in private wealth planning. Developments such as the UBO register and various DAC reporting regimes have significantly expanded the information available to tax authorities across bor - ders. At the same time, changes affecting traditional pri - vate wealth structures, including Dutch open limited partnerships and certain family fund structures, have prompted many families to reassess their existing arrangements. The focus has therefore shifted. Rather than asking whether a structure provides privacy, families increas - ingly ask whether it remains robust, defensible and sustainable in a fully transparent environment.
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