The exempt investment fund regime exists next to the fiscal investment fund regime described above. In the time ahead, the government is going to investigate the desirability of the measure as well as any accompanying measures. The intention is that the real estate measure is included in the 2024 Tax Plan package. No change will be made for fiscal investment funds investing in securities. The real estate measure is intended to ensure that profits earned from real estate can, in all cases, be taxed with CIT and that an effective levy is guaranteed, including, for example, in all cases in which foreign investors invest in Dutch real estate. The government has announced that, as of 1 January 2025, a measure is to be introduced on the basis of which fiscal investment funds will no longer be able to invest directly in real estate (real estate measure). Examples are conference facilities or the exploitation of an in-house restaurant. Fiscal investment funds that invest in real estate are allowed to hold a taxable subsidiary that provides customary services in relation to the real estate held by the Dutch real estate investment trust (REIT). In general terms, under the existing fiscal investment fund regime, the CIT rate for fiscal investment funds is 0%, provided that their profit is made available to the shareholders and holders of certificates of participation no later than eight months after year-end.įiscal investment funds may also invest in real estate development (or redevelopment) activities, provided that these activities take place through a subsidiary subject to Dutch CIT and the development (or redevelopment) activities are exercised for the benefit of real estate that is (or will be) forming part of the fund’s own portfolio, an affiliated fiscal investment fund’s portfolio, the portfolio of a company in which the fund or the affiliated fund has a substantial interest, or for the benefit of the subsidiary’s own portfolio ('project development' subsidiary). The standard rate applies to the excess of the taxable income.

A lower rate of 19% (15% in 2022) applies to the first income bracket of EUR 200,000 (EUR 395,000 in 2022). Non-resident entities only have a limited tax liability with regard to income from Dutch sources. However, certain income can be exempted or excluded from the tax base. In general, a Dutch resident company is subject to CIT on its worldwide income.

Federal tax brackets 2021 over 65