Although the Dutch FBI regime had its advantages the fund managers established their funds in many cases in different jurisdictions. In order to make the Dutch regime more interesting a second regime was introduced in 2007. This regime gives investment funds the opportunity to be exempted from corporate tax. This regime has the following aspects:
It’s not possible to invest directly in real estate through a VBI. The VBI can however, through shares, invest in real estate indirectly. Although it was not intended to create a new regime for substantial shareholders, the new regime appeared to be very attractive for them. In case a second shareholder with a stake of at least 10% holds shares in the Dutch VBI it is possible to receive the special regime.