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ARTICLE · 12 MAY 2011

UCITS IV – Amendments In Dutch Tax Laws

De Brauw Blackstone Westbroek
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The Dutch Finance Minister has submitted to parliament a proposal to amend Dutch tax laws in connection with the implementation of the UCITS IV Directive.

NetherlandsTax
Kees Groffen
Kees Groffen
Dick Hofland
Dick Hofland
Bernard Spoor
Bernard Spoor
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The Dutch Finance Minister has submitted to parliament a proposal to amend Dutch tax laws in connection with the implementation of the UCITS IV Directive.

Tax residency

The UCITS IV Directive allows a management company to manage UCITS which are established and supervised in another country. The proposal establishes that for Dutch tax purposes these UCITS will be deemed to have their place of management in such country and therefore will not become a tax resident of the Netherlands even if they would have their actual place of management in the Netherlands.

FBI status

The UCITS IV Directive allows UCITS to invest at least 85% of their assets in other UCITS, thus enabling master-feeder structures. The Dutch Corporate Income Tax Act is amended in order to allow non-Dutch feeder-UCITS to invest in Dutch master-UCITS which qualify as fiscal investment institutions (fiscale beleggingsinstelling or "FBI"). The Dutch Finance Minister expects that Dutch master-UCITS

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