Investment vehicles

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The Dutch Ministry of Finance is actively engaged in obtaining and maintaining a prominent
international position in the field of investment funds for the Netherlands.

This pursuit has resulted in a highly competitive mixture of both flexible entities and favourable tax regimes. Examples of the latter are the Dutch Fiscal Investment Institution (“FII”) and the Exempt Investment Institution (“EII”). The FII is taxed at a 0% corporate income tax rate, while the EII is tax exempt. Examples of flexible entities are the fund for joint account (“FGR”) and the Cooperative (“COOP”). The FGR is widely used as a transparent asset pooling vehicle and can be tailored to the specific needs of a funds in great detail. The COOP, on the other hand, is an non transparent entity usually exempt from dividend withholding tax obligations.

For the purpose of a preliminary outline, we restrict ourselves to a limited overview of possibilities. We refer to our brochure Dutch investment vehicles on our website 2 for an extensive review of this subject.

Entity	subject to corporate income tax	subject to dividend withholding tax	Eligible to tax treaty/ Eu directive	share- holder require ments	Investment requirements
Transparent funds	No	No	No/No	No	No
FII	0%	15%*	Yes/No	Yes	Yes
EII	Exempt	Exempt	No/No	Yes	Yes
Taxable corporation funds	25%	15%**	Yes/Yes	No	No
COOP	25%	Exempt***	Yes/Yes	No	No

* Might be reduced by a tax treaty or Dutch unilateral provisions
** Might be reduced by a tax treaty, an Eu Directive or Dutch tax law
(in case of Eu corporate entities and pension funds)
*** Provided no specific anti-abuse regulations apply

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