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ARTICLE · 12 AUGUST 2026

Recent Tax Developments For Dutch Pension Funds

Loyens & Loeff
Loyens & Loeff
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Loyens & Loeff

Loyens & Loeff

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The EU's Taxation Omnibus proposal aims to expand the Parent-Subsidiary Directive to include pension funds and eliminate minimum ownership thresholds, potentially removing significant tax obstacles for cross-border EU investments. Meanwhile, the Netherlands has introduced temporary relief measures for collective investment vehicles (FBIs) affected by recent tax classification reforms, providing a pragmatic solution for pension funds navigating new transparency requirements.

NetherlandsTax

Recent tax developments at both EU and Dutch level may have important implications for Dutch pension funds and the structures through which they invest. This includes the proposal for the EU “Taxation Omnibus” that was published by the European Commission on 24 June 2026. Furthermore, the Dutch Ministry of Finance published a decree on 22 June 2026 including temporary relief for fiscal investment institutions (fiscale beleggingsinstellingen; FBIs) that are affected by the reform of the Dutch tax classification framework as of 1 January 2025.

EU Taxation Omnibus

The Taxation Omnibus proposal introduces amendments to various EU directives relating to direct taxation, among others, the Parent-Subsidiary Directive (PSD). The proposal aims to simplify EU tax rules, cutting administrative burdens and strengthening the competitiveness of the EU market.

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