Global site
Africa
Americas
Asia Pacific
Europe
Middle East

Nederlands

Services

You want your attention to be on growing and developing your company. You require (financial) advice about issues such as: whether to take care of your...

See Overview

Financial administration
An accurate financial administration provides you with the information you need to take the right decisions. The big advantage of a digital financial administration is that it provides insight into your most important financial processes at any time, whether this is the invoices, salary payments or bank changes.
Financial insight
You want to take the right decisions, based on trustworthy and clear management information. You want to have access to all your financial data, 24/7, in order to determine your position and be able to adjust where necessary.
Global compliance partnering
Outsourced compliance services comprises the total financial compliance of your business, in accounting, financial reporting, payroll, legal and various tax reporting obligations. We can make sure you don’t have to worry.

Related insights:

30% Ruling Important Changes to the 30% Ruling per 1 January 2024

On 26 October 2023, the Dutch House of Representative (Tweede Kamer) voted in favour of two amendments which will likely alter the current 30% tax ruling facility.

Louis de Vries

| 3 min read | 01 Jan 2024

Advisory

Everyone – companies, entrepreneurs and individuals – has to deal with taxes. A complex system of payments and levies, tax regimes also offer opportunities for...

See Overview

Impact House by Grant Thornton
Building sustainability and social impact. That sounds good. But how do you go about it in the complex world of stakeholders, regulations and frameworks and changing demands from clients and society? How do you deal with important issues such as climate change and biodiversity loss?
Business risk services
Minimize risk, maximize predictability, and execution Good insights help you look further ahead and adapt faster. Whether you require outsourced or co-procured internal audit services and expertise to address a specific technology, cyber or regulatory challenge, we provide a turnkey and reliable solution.
Corporate finance
Finding a suitable match at the most optimum terms. That, in a nutshell, aptly describes the objective of mergers and acquisitions. To most businesses mergers or acquisitions are not standard daily practice. It is, however, for the professionals at Grant Thornton! Seeking their services will add value instantly.
Cyber risk services
What should I be doing first if my data has been kidnapped? Have I taken the right precautions for protecting my data or am I putting too much effort into just one of the risks? And how do I quickly detect intruders on my network? Good questions! We help you to answer these questions.
Transaction services
What will the net proceeds be after the sale? How do I optimise the selling price of my business or the price of one of my business activities? How do I capitalise on synergies following an acquisition? Am I not offering too much? These are all good questions when you’re buying or selling a business. It’s a transaction that concerns significant amounts, impacts your future, and therefore must be executed properly. We provide a solid foundation for your decisions.
Valuation, investigation & dispute services
Do you require a fact finding investigation to help assess irregularities? Is it necessary to ascertain facts for litigation purposes?

Related insights:

AI Understanding the implications of the AI Act and AI Governance

Artificial Intelligence (AI) is transforming industries globally, offering unprecedented opportunities for innovation, efficiency, and growth. However, alongside these opportunities come significant challenges, and risks.

| 4 min read | 17 Oct 2024

Audit & assurance

Reliability of information. The way in which reliable information is produced. That is what assurance is all about. It is crucial for information to be...

See Overview

Auditing of annual accounts
You are answerable to others, such as shareholders and other stakeholders, with regard to your financial affairs. Financial information must therefore be reliable. What is more, you want to know how far you are progressing towards achieving your goals and what risks may apply.
IFRS services
Financial reporting in accordance with IFRS is a complex matter. Nowadays, an increasing number of international companies are becoming aware of the rules. But how do you apply them in practice?
ISAE & SOC Reporting
Our ISAE & SOC Reporting services provide independent and objective reports on the design, implementation and operational effectiveness of controls at service organizations.
Pre-audit services
Pre-audit services is all about making the company’s entire financial administration ready for checking before the external accountant begins his/her audit of the annual accounts.
SOx law implementation
The SOx legislation dictates that management is structurally accountable for reporting on the internal control relevant to the financial statements.

Related insights:

GTIL GTIL responds to the sustainability standards proposed in Europe

GTIL has submitted its response to EFRAG on the draft European Sustainability Reporting Standards (ESRS).

3 min read | 09 Sep 2022

Tax

Do you have an ambitious international company? And do you want to stay ahead of the competition? Then you need to be able to rely on the best international...

See Overview

International corporate tax
The Netherlands’ tax regime is highly dynamic. Rules and the administrative courts raise new challenges in fiscal considerations on a nearly daily basis, both nationally and internationally.
VAT advice
VAT is an exceptionally thorny issue, especially in major national and international activities. Filing cross-border returns, registering or making payments requires specialised knowledge. It is crucial to keep that knowledge up-to-date in order to respond to the dynamics of national and international legislation and regulation.
Customs
Importing/exporting goods to or from the European Union involves navigating complicated customs formalities. Failure to comply with these requirements usually results in delays. In addition, an excessively high rate of taxation or customs valuation for imports can cost you money.
Human Capital Services
Do your employees determine the success and growth of your organisation? And are you in need of specialists which you can ask your Human Resources (HR) related questions? Human Resources (HR) related questions? Our HR specialists will assist you in the areas of personnel and payroll administration, labour law and taxation relating to your personnel. We provide you with high-quality personnel and payroll administration, good HR guidance and the right (international) advice as standard. All this, of course, with a focus on the human dimension.
Innovation & grants
Anyone who runs their own business sets themselves apart from the rest. Anyone who dares stick their neck out distinguishes themselves even more. That can be rather lucrative.
Tax technology
Driven by tax technology, we help you with your (most important) tax risks. Identify and manage your risks and become in control!
Transfer pricing
The increased attention for transfer pricing places greater demands on the internal organisation and on reporting.
Sustainable tax
In this rapidly changing world, it is increasingly important to consider environmental impact (in accordance with ESG), instead of limiting considerations to financial incentives. Multinational companies should review and potentially reconsider their tax strategy due to the constantly evolving social standards
Pillar Two
On 1 January 2024 the European Union will introduce a new tax law named “Pillar Two”. These new regulations will be applicable to groups with a turnover of more than EUR 750 million.
Cryptocurrency and digital assets
In the past decade, the utilization of blockchain and its adoption of a distributed ledger have proven their capacity to revolutionize the financial sector, inspiring numerous initiatives from businesses and entrepreneurs.
Streamlined Global Compliance
Large corporations with a presence in multiple jurisdictions face a number of compliance challenges. Not least of these are the varied and complex reporting and compliance requirements imposed by different countries. To overcome these challenges, Grant Thornton provides a solution to streamline the global compliance process by centralizing the delivery approach.

International business

Expanding into new international markets can be challenging. Where should you expand, how and when? As an international business adviser we can help!

See Overview

Expand into new markets
Do you seek for opportunities in the global business arena? Whether you are about to open a new office in a foreign country or considering an international acquisition, you need certainty of making the right choices for your company. Global expansion isn’t always as simple as it sounds. The good thing is that we’re here to help!
Expanding your business in the Netherlands
International expansion is an important step. The Netherlands can be your gateway to Europe for doing business abroad. But why you should choose the Netherlands?
Global contacts
Wherever you choose to do business, you want access to people with the best ideas and critical thinking that will enable you to grow your business at home and abroad.

Legal services

Our corporate lawyers can advise and support you with regard to a wide range of areas at both national and international level.

See Overview

Corporate Law
From the general terms and conditions to the legal strategy, these matters need to be watertight. This provides assurance, and therefore peace of mind and room for growth. We will be pro-active and pragmatic in thinking along with you. We always like to look ahead and go the extra mile.
Employment Law
Small company or large multinational: in any company your people are of the utmost importance for your business. Employment brings with it many issues in many areas and often has legal consequences. For big strategic, but also for more everyday questions about employment law, our lawyers are ready to help you out. Also for questions about international employment law. Do you have your own HR department? We’ll gladly assist them. We deliver bespoke services and are there when you need us.
Sustainable legal
Sustainability is more than a buzzword - it is the core of our legal advice towards sustainable success. From drafting sustainable contracts, integrating sustainable HR policies and ESG due diligence within our M&A practice to advising on ESG and other (national and international) legislation: we prefer to be pragmatic and proactive in helping your business.

Industries

Real estate & construction

The building and real estate sector is facing a lot of challenges. Improving sustainability, innovation, but also transformation are important themes. By...

See Overview

Family businesses

Family businesses occupy a unique position, in the Netherlands as well as worldwide. They are seen as a (stable) engine of the economy. This is characterized,...

See Overview

Transport & logistics

The Netherlands is a real trading country, due to its location, infrastructure and the highly-educated population. The port of Rotterdam, the biggest port in...

See Overview

Maritime sector
How can you continue to be a global leader? The Netherlands depends on innovation. It is our high-quality knowledge which leads the maritime sector to be of world class.

Related insights:

Pillar 2 Pillar 2 and the tonnage regulation: watch out for possible additional taxation!

Starting in 2024, a new law for a global minimum profit tax for internationally operating companies will apply in the Netherlands: the 2024 Minimum Tax Act (Pillar 2).

Mirjam Zeldenrust

| 3 min read | 26 Jun 2023

Tax Laws

Tax Consequences of Proposed Laws: Open CVs and Open FGRs

By:

Dooitze Dijkstra,

Loic Weissglas

15 Jan 20244 min read

Open CVs and Open FGRs - smiling businesswoman using laptop

Open Limited Partnerships (open CVs) and Open Collective Investment Schemes (open FGRs), also known as family funds, are facing significant tax changes. Two legislative proposals, introduced on Budget Day 2023, aim to adjust the tax treatment of these entities, with potentially significant implications for their tax obligations and fiscal benefits. It is crucial to have early insight into these changes and consider measures to mitigate potential adverse tax consequences.

Contents

Background

The draft ‘Tax Qualification Policy for Legal Forms’ law aims to prevent hybrid mismatches in international contexts, particularly for open limited partnerships (open CVs) and open common funds (open FGRs). This proposal aims to limit tax avoidance by preventing the unintended use of these structures. The government wants to no longer treat open CVs and open FGRs as corporations. This could lead to unexpected income or corporate tax in the form of a final settlement for these legal forms.

The Proposal

The proposal for open limited partnerships (open CVs) and open common funds (open FGRs) was presented on Budget Day 2023. Originally, it was intended that the proposal would enter into force on January 1, 2024. However, to give taxpayers more time to restructure, the entry into force has been postponed. This means that the transitional rules, including the carry-over facilities, will apply in the year 2024. The changes to the legislation, such as the new definition of the common fund and the abolition of the open limited partnership, will now enter into force on January 1, 2025.

Impact on open CVs

One of the most significant impacts of the proposal is that the tax liability for open CVs will be eliminated. This means that open CVs will become ‘fiscally transparent’ and that taxation will occur at the partners instead of at the open CV itself. This could mean that open CVs will be subject to income tax (for individuals as partnerships) and/or corporate tax (for legal entity as partnerships). This could have profound consequences for tax planning and asset structuring.

Repercussions for open FGRs (Family Funds)

For open FGRs, also known as family funds, the definition of this legal structure will be altered. This will result in open FGRs being less likely to be classified as taxable for corporate tax. Open FGRs are also anticipated to become fiscally transparent, which implies that taxation will occur at the participants of the fund. These adjustments have particularly significant ramifications for family funds that use the open FGR structure.

Note to the proposal

On November 17, 2023, the official response to the proposal was issued. The committee handling the response inquired about the government's stance on the proposal. The official response to the proposal ‘Tax Qualification Policy for Legal Forms’ affirms that anonymizing assets is not a valid reason to keep the open limited partnership (open CV). The abolishment of the tax obligation of the open CV only applies to Dutch tax regulations. This is independent of the UBO regulations in the Netherlands for CVs, as the internationally unusual authorization requirement is being eliminated. This aids in preventing tax qualification discrepancies.

Regarding the potential unremitted losses due to the loss carry-forward rule, the state secretary confirms that there will be a carry-over provision in the transitional rules. The transitional law, including provisions for rollover facilities and deferred payment arrangements, applies in the year 2024. Amendments to the regulations, such as the revised definition of the mutual fund and the abolition of the open limited partnership, will take effect from January 1, 2025.

Additionally, an administrative regulation (AMvB) will be developed for the legal form comparison method, which will incorporate further guidelines and a list of acceptable foreign legal forms. This AMvB will be subjected to public comment in the first quarter of 2024.

Finally, the cabinet has included a transitional measure in the proposal to prevent dividend withholding tax. Since dividend withholding tax has been in place for interest and royalties since January 1, 2021, the cabinet sees no reason to expand the transitional rules for this purpose.

Recommended Action

It is critical to anticipate the proposal in a timely manner and to examine potential measures to avoid negative tax consequences. Although the specific steps are not yet known, it is advisable to map out in advance how these modifications will affect your particular circumstance.

Conclusion

The proposed legislation for open CVs and open FGRs could have significant tax consequences for the participants of these legal structures. It is critical to stay informed about these developments and to consider potential measures to prevent negative tax consequences.

We would be happy to assist you in assessing the potential consequences and discovering appropriate solutions for open CVs and open FGRs.