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ARTICLE · 17 JANUARY 2016

Conditions Relaxed For Dutch Master-Feeder LP And Mutual Investment Fund Structures

De Brauw Blackstone Westbroek
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The Dutch State Secretary of Finance has issued amended decrees on the Dutch tax treatment of limited partnerships (LPs) and funds for joint account (FGRs).

NetherlandsTax
De Brauw Blackstone Westbroek N.V
De Brauw Blackstone Westbroek N.V
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The Dutch State Secretary of Finance has issued amended decrees on the Dutch tax treatment of limited partnerships (LPs) and funds for joint account (FGRs). Dutch LPs and FGRs are frequently used as investment funds because of their flexibility and tax efficiency. The key change is that the amended resolutions simplify the requirements that the State Secretary of Finance believes should be met in order to secure a Dutch tax transparent treatment of master-feeder structures involving LPs or FGRs. Where previously the transfer or issue of partnership interests in a feeder or master required the consent of all partners of both the master and feeder, under the new rules only the consent of the partners in the relevant master or feeder is required. This new rule applies from 1 January 2016. To benefit from this simplification, funds should include the simplified consent in the fund documentation or, in the case of existing funds, inform the Dutch tax authorities that

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