EEI Regime

Limitation of the Exempt investment Institution Regime

Johan Loo,
Danjella van Gog
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Do you invest private assets using the Exempt Investment Institution (EEI) regime? The government has proposed to amend the EEI-regime as per 1 January 2025. Consequently, you will no longer have the possibility to use the EEI-regime when investing private assets. Why is this change necessary and what are the implications for you?

Why is this modification necessary?  

In 2007, the EEI-regime was introduced into the Dutch Corporate Income Tax. The EEI-regime aims to facilitate collective investment, by avoiding additional taxation at the level of investment institutions in comparison with direct investments.

An investment institution that meets the legal requirements for the EEI-regime is subjectively exempt from corporate income tax. Research has shown that the EEI-regime was particularly used by non-targeted users, such as wealthy individuals or families. For this reason, the government has proposed a modification of the EEI-regime. We elaborate on this modification below. 

Proposal modification EEI-regime  

Under the proposed measures, the EEI-regime will be limited. As a result, the EEI-regime will only apply to investment institutions regulated under the Dutch Financial Supervision Act as of 1 January 2025. With this modification, the government aims to eliminate the existing possibility to use the EEI-regime when investing private assets of participants. 

Does this proposal also affect you? 

Curious if this change might have any implications for you?

Reach out to one of our specialists and ask for advice!