ARTICLE · 12 JANUARY 2023

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Dutch Tax Entity Classification Rules: Looking Ahead For Real Estate Funds

Alvarez & Marsal

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In the second quarter of 2023, a legislative proposal is expected to be published to amend the Dutch tax entity classification rules. This proposal will, most notably, include the abolishment...

United KingdomTax

In the second quarter of 2023, a legislative proposal is expected to be published to amend the Dutch tax entity classification rules. This proposal will, most notably, include the abolishment of the so-called unanimous consent requirement for Dutch and foreign limited partnerships (LPs) to qualify as transparent for Dutch direct tax purposes. As a result, LPs will in principle qualify as transparent going forward. The abolishment is expected to be implemented together with a deemed disposal rule for tax opaque LPs and limited partners that are subject to Dutch corporate income tax. This could possibly lead to exit taxation unless certain tax facilities are made available. Timely impact assessments are recommended, as the abolishment could be effective as soon as 1 January 2024. This publication outlines the potential impact for the real estate funds industry.

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