The corporate, partnership and fund vehicles used in the Netherlands to hold and manage investments — from the B.V. and CV to the FGR and regulated fund structures.
The Netherlands offers a range of vehicles for holding and pooling investments, from simple corporate holdings to regulated fund structures. The right vehicle depends on whether investors want a taxable corporate entity or a tax-transparent one, whether the structure is regulated, and how many investors participate.
Corporate vehicles such as the B.V. are taxed in their own right and benefit from the participation exemption. Partnership and contractual vehicles such as the CV and FGR are commonly tax-transparent, so income is taxed at investor level. Fund structures add a regulatory layer supervised by the AFM and DNB. See the investment SPV and investment platforms pages for related structures.
Private limited company — the standard corporate holding and SPV vehicle. Taxable, with access to the participation exemption.
Public limited company used for larger groups and listed structures, and occasionally for investment platforms.
Limited partnership, commonly tax-transparent. Used for private equity and venture fund structures with a general and limited partners.
Contractual fund for joint account. A pooling vehicle that can be transparent or opaque depending on its terms.
Cooperative association, historically used in holding and investment structures for its membership-based flexibility.
AIF and UCITS-type structures supervised by the AFM, used for collective investment with external investors.
| Vehicle | Nature | Tax treatment | Typical use |
|---|---|---|---|
| B.V. | Corporate, limited liability | Taxable; participation exemption | Holdings, SPVs, subsidiaries |
| N.V. | Corporate, limited liability | Taxable; participation exemption | Large groups, listed vehicles |
| CV | Limited partnership | Commonly transparent | PE / VC fund structures |
| FGR | Contractual fund | Transparent or opaque | Pooling of investor capital |
| Cooperatie | Membership association | Taxable; flexible | Holding & investment structures |
| Regulated fund | Collective investment | Depends on regime | External-investor funds |
Selecting a vehicle involves balancing tax, regulatory and commercial considerations. Key questions include:
For single-asset deals a B.V. SPV is often sufficient; for multi-investor pooled capital a CV, FGR or regulated fund may be more appropriate.
Investment vehicles must be assessed against both tax substance rules and, where relevant, financial regulation. Fund activity may require registration or a licence with the AFM under AIFMD, while access to the participation exemption and treaty benefits depends on genuine substance and anti-abuse compliance under the OECD BEPS framework and ATAD. See substance requirements and the corporate tax guide.
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