It is intended to prevent investment funds qualifying as non-transparent (independently taxable) for a short period of time when the new rules take effect on January 1, 2025.
We recommend that all parties involved in the issue, resale or redemption of vouchers review the VAT treatment of their activities based on this ruling.
The Advocate General believes that Dutch pension funds are not sufficiently comparable to a UCITS for them to be regarded as a special investment fund.
On January 19, 2024 the Dutch Supreme Court clarified the rules applying to the crediting of dividend withholding tax for corporate income tax purposes.