Temporary Relief For FBIs Affected By Dutch Tax Classification Reforms

The Dutch State Secretary of Finance issued a decree dated 22 June 2026 introducing a temporary approval for FBIs, which face practical challenges resulting from the Dutch tax classification reforms that came into force on 1 January 2025. This relief is very welcome and helpful for FBIs that hold investments in funds that were non-transparent and that have become tax transparent from a Dutch perspective as of 2025.

Background

The fiscal investment institutions (fiscale beleggingsinstellingen; FBIs) regime is a tax-neutral regime for collective investment vehicles. Broadly, it effectively eliminates taxation at the level of the investment institution and shifts taxation to the level of the investors through the annual requirement to distribute profits. The regime is subject to strict statutory requirements, including the distribution requirement and the financing limitation.