Today, the Dutch Ministry of Finance announced that it changed its policy on Exempt Investment Institutions (Vrijgestelde Beleggingsinstellingen or VBIs) in the sense that from now it will support these entities if they claim protection under Dutch tax treaties, except if the Netherlands specifically agrees with the other treaty partner that certain treaty benefits will not be available. The Dutch tax authorities will assist Exempt Investment Institutions in claiming tax treaty protection by issuing residency certificates. This will make the Exempt Investment Institution an interesting alternative to Fiscal Investments Institutions (Fiscale Beleggingsinstellingen or FBIs) and similar foreign tax-exempt investment vehicles.
The Exempt Investment Institution regime is a special tax-exempt regime for (semi-)open-end collective investment schemes investing in certain classes of financial instruments.
A high-level tax comparison of the Exempt Investment Institution with tax treaty eligibility, the Fiscal Investment Institution and the Luxembourg SICAV regime is included in the annex.